november 21, 2011, "mortgage foreclosure - vacant possession syndicate" 50 members are identified,...

7/31/2019 November 21, 2011, "Mortgage Foreclosure - Vacant Possession Syndicate" 50 members are identified, including

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Court File Number: FC -210-11IN THE COURT OF QUEENS BENCH OF NEW BRUNSWICKTRIALDMSIONJUDICIAL DISTRICT OF FREDERICTONBETWEEN:

ANDRE MURRAYPlaintiff,

-and-

COURT OF QUEEN'S BENCHFRED~RICTON, NBRECEIVt:D A ND != IL ED

BEITY ROSE DANIELSKI,RICHARD BOILEAU,RQBERT C. JONES,GINO DUGUAY,HOME ALONE PROPERTY MANAGEMENT SERVICESLIMITED,HUGH K. CAMERON,SUELLEN ROSS,COX &PALMER,STEWART MCKELVEY,VALERIE CALDWELL,PROVINCIAL SECURITY &INVESTIGATION SERVICESLTD.,DAVE DANELRJK A.K.A. DAVID A. DANELIUK,HUGH J.CAMERON,CANDY LEBLANC,GEORGE H.LEBLANC,ROYAL BANK OF CANADA,STEVEN J.HILL,ATLANfIC DOClJMENf S,ERVICE LTD.,JULIE RUGGIERO,ANDREEN TRANCIlELL,CITY OF FREDERICTON,FREDt;RICTON POLICE FORCE,CHIEF QF POLICE BARRY MACKNIGHT,CONS,{ABLE D. BECK,CONSTABLE A YERXA,CONSTABLEC.HAINES,JUSTICE AND CONSUMER AFFAIRS, N O V 2 1 2 0 1 1cous DU BANe DE LA REINEFREDERICTON N-,8 ,REC;U E T D E POSE

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SHERIFF SERVICES,SHERJFF KEITH F. BALL,DEPUTY SHERIFF CLARENCE MORENCY,DEPUTY SHERIFF DALE G. KOZAK,ARA FREDERICTON APPRAISAL ASSOCIATES LTD.,JOHN CARTER,CENTRACT REAL PROPERTY RECOVERY SERVICES,RICHARD MCGUIGAN,MICHAEL MCWILLIAM,BINGHAM ROBINSON MACLENNAN EHRHARDT TEEDEDWIN G. EHRHARDT,DANAH SMITH,BEV MCAFFEE,NEIL RODGERS,BRIAN PARKER,GHISLAIN BERNARD,GARY STEELE,PATRICIA BOUDREAU,PETER ATKINSON,501376 N.B. Ltd. a body corporateARA FREDERICTON APPRAISAL ASSOCIATES LTD.D. HAROLD MOORE

DefendantsSTATKMENT OF CLAIM

(FORM 16C)(Notice of Action issued on z o " day of October, 2 P 11)

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STATEMENT OFCLAIMSet out in separate, numbered paragraphs the following:(The capacity of all persons who are parties to the proceeding.)

THE PARTIES to the proceeding1. Plaintiff Andre Murray is residing at his 31 Marshal Street, Fredericton, NewBrunswick residential leasehold tenancy since year 2005.2. Defendant Betty Rose Danielski Apt 603, 166Carlton St, Toronto, Ontario, M5A 2K5.3. Defendant Richard Boileau's address is unknown at this time.4. Defendant Robert C. Jones - director of Rome Alone Property ManagementServices Limited website list address 10 Ann St Mississauga, Ontario, Canada L5G 3E6.5. Defendant Gino Duguay, Affidavit claims address as Sheffield, New Brunswick.6. Defendant Rome Alone Property Management Services Limited website listed theaddress as 10 Ann St Mississauga, Ontario, Canada L5G 3E6.7. Defendant Hugh K. Cameron, is a Process Server and Director of CameronAuctioneers and Appraisers Ltd. 857 Rte. 8 Hwy, Taymouth, New Brunswick, E6C 2B5.8. Defendant Suellen Ross is a Auctioneer employed by Cameron Auctioneers andAppraisers Ltd. at 857 Rte. 8 Hwy, Taymouth, New Brunswick, E6C 2B5.9. Defendant Cox &Palmer is a law Firm with the relative Moncton Office located atBlue Cross Centre Suite 500, 644 Main Street, Moncton, NB E1C lE210. Defendant Stewart McKelvey is a law Firm with the relative Fredericton Officelocated at Suite 600, Frederick Square, 77 Westmorland Street, Fredericton, NB, Canada.11. Defendant Valerie Caldwell assistant to Defendant Hugh J. Cameron at StewartMcKelvey, Suite 600, Frederick Square, 77 Westmorland Street, Fredericton, NB.12. Defendant Provincial Security & Investigation Services Ltd. is Fredericton basedoffering inter alia Bailiff &Process Service. ( ) offersaddress as Post Office Box 3234 Stn "B", Fredericton NB E3A 5G9.13. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, an owner operator ofProvincial Security & Investigation Services Ltd. P.O. Box 3234 Stn "B", Fredericton NBE3A 509, formed in 1999; employees himself to act as a Process Server.

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14. Defendant Hugh J. Cameron, partner at Stewart McKelvey, Barristers, Solicitorsand Trademark Agents, office located at Suite 600, Frederick Square, 77 WestmorlandStreet, P.O. Box 730 Fredericton NB, Canada" E3B 5B4.15. Defendant Candy LeBlanc assistant to Solicitor George H. LeBlanc, Partner atCox &Palmer, Moncton Suite 502,644 Rue Main Street, Moncton, NB EIC lE2.16. Defendant George H. LeBlanc is a Solicitor, a Partner at Cox &Palmer, with aMoncton, N.B. office at Suite 502, 644 Rue Main Street, Moncton, NB El C lE2.17. Defendant Royal Bank of Canada a financial investment institution, providinginter alia Banking Services, at 1, Place Ville-Marie Montreal, Quebec, Canada, H3B 2E7.18. Defendant Steven J. Hill is a Solicitor agent for Defendant George H. LeBlanc;Cox &Palmer Suite 400,371 Queen Street, PO Box 310, Fredericton, NB, E3B 4Y919. Defendant Atlantic Document Service Ltd. has a Office located at 106 GreywoodCourt, Riverview, New Brunswick, E1B 5N2.20. Defendant Julie Ruggiero, a 'Collections' Associate for Royal Bank:of Canadawith a office reportedly located inMontreal Quebec, Canada.21. Defendant Andreen Tranchell, a Property Management Coordinator for CentractReal Property Recovery Services, office 39 Wynford Drive, Toronto, ON M3C 3K5.22. Defendant Centract Real Property Recovery Services Inc, Office located at 39Wynford Drive, Toronto, ON M3C 3K5.23. Defendant, THE CITY OF FREDERICTON, has City Hall office located at 397Queen Street, Fredericton New Brunswick, Canada.24. Defendant, FREDERICTON POLICE FORCE, Head Office is located at 311Queen Street, Fredericton, NB, E3B IB 1.25. Defendant CHIEF OF POLICE Barry MacKnight of FREDERICTON POLICEFORCE a Head Office at 311 Queen Street, Fredericton, NB, E3B 1B1.26. Defendant D. Beck, with rank of Constable as a member of FREDERICTONPOLICE FORCE Office located at 311 Queen Street, Fredericton, NB, E3B 1B1.27. Defendant C. Haines, with rank of Constable as a member of FREDERICTONPOLICE FORCE Office located at 311 Queen Street, Fredericton, NB, E3B 1B1.28. Defendant A. Yerxa, with rank of Constable as a member of FREDERICTONPOLICE FORCE Office located at 311 Queen Street, Fredericton, NB, E3B lBI.

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29. Defendant New Brunswick, Department of Justice and Consumer Aj]'airs, Officelocated at Centennial Building, 670 King St Fredericton, NB E3B 101.30. Defendant Fredericton Sheriff Services, Regional Office, is located at JusticeBuilding 427 Queen Street, Fredericton, New Brunswick E3B IB7.31. Defendant KEITH F. BALL is Sheriff of Fredericton Sheriff Services, RegionalOffice, Justice Building 427 Queen Street, Fredericton, New Brunswick E3B IB7.32. Defendant Clarence Morency, a Deputy Sheriff employed at Fredericton SheriffServices, Regional Office 427 Queen Street Fredericton, New Brunswick E3B IB7.33. Defendant Dale G. Kozak, a Deputy Sheriff employed by Fredericton SheriffServices, Regional Office 427 Queen Street Fredericton, New Brunswick E3B IB7.34. Defendant ARA Fredericton Appraisal Associates Ltd., office is located at 102-3Main Street, Fredericton, New Brunswick, E3A 9N635. Defendant John C. Carter, Residential Appraiser employed by ARA FrederictonAppraisal Associates Ltd. 102-3 Main Street" Fredericton, New Brunswick, E3A 9N6.36. Defendant Peter E. Atkinson, Residential Appraiser employed by ARA FrederictonAppraisal Associates Ltd 102-3 Main Street" Fredericton, New Brunswick, E3A 9N6.37. Defendant D. Harold Moore, President of ARA Fredericton Appraisal AssociatesLtd office located at 102-3 Main Street, Fredericton, New Brunswick, E3A 9N6.38. Defendant Richard McGuigan P.Eng, office is located at 211 Doak Road,Fredericton, NB E3C 2E6.39. Defendant Michael A. McWilliam is a Solicitor a Partner at Cox &Palmer, officeis located at Blue Cross Centre, Suite 502, 644 Rue Main Street, Moncton, NB E 1C 1E2.40. Defendant Edwin G. (Ted) Ehrhardt, a Partner at Bingham Law (BinghamRobinson MacLennan Ehrhardt Teed) with a office is located at Heritage Court 95Foundry Street, Suite 300 Moncton, NB, Canada EIC SH7.41. Defendant Bev McAffee Legal Assistant to Edwin (Ted) Ehrhardt, office islocated at Heritage Court 95 Foundry Street, Suite 300 Moncton, NB, Canada EIC 5H742. Defendant Danah Smith Paralegal at Bingham Law office 95 Foundry Street"Suite 300 Moncton, NB, Canada EIC SH7.43. Atlantic Document Service Ltd. Office located at 106 Greywood Crt, Riverview,NBE1B 5N2

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44. Defendant Bingham Robinson MacLennan Ehrhardt Teed, 95 Foundry Street,Suite 300, Moncton, New Brunswick, Canada, EtC 5H745. Defendant Neil Rodgers, 15 Fisher Ave, Fredericton, New Brunswick, E3A 41146. Defendant Brian Parker, 27 Marshall Street, Fredericton, New Brunswick" E3A 4J847. Defendant GhislainBemard, 231 Champlain St-Suite 100, Dieppe, NewBrunswick, E1A IN9.48. Defendant Gary Steele, 651 Loyalist Crt, Fredericton, New Brunswick E3B 3K949. Defendant 501376 N.B. Ltd. a body corporate,211 Doak Road, Fredericton, NBE3C 2E6

The capacity of all persons who are parties to the proceeding50. Plaintiff Andre Murray has been illegal and unlawful actions for that reasonsuffered damages furthermore, by the negligent actions and or lack of care to avoidcausing harm by the various named Defendants to this Action.51. Defendant Betty Rose Danielski confirmed with the Land Titles Registry Service ofNew Brunswick, Queens Street, Fredericton as the Registered Titleholder for theresidential duplex property 29 Marshall Street and 31 Marshall Street, Fredericton.52. Defendant Richard Boileau, was assigned POWER OF ATTORNEY FORPROPERTY, by Betty Rose Danieslki to act on her behalf, furthermore DefendantRichard Boileau did sign various contracts with Andre Murray regarding the MarshallStreet, Duplex Property on behalf of Betty Rose Danieslki. Including ResidentialTenancy Leases for both of the Duplex civic addresses 29 &31 Marshall Street,Fredericton.53. Defendant Robert C. Jones director of Rome Alone Property Management ServicesLimited is doing business as Home Alone Property Management Services Limited, inNova Scotia, Canada. Furthermore, claims to be providing agents service to Royal Bankof Canada, who acted on the 29 Marshall Street and 31 Marshall Street, Fredericton, NewBrunswick duplex property, before, during and after alleged mortgage sale at auction July16,2009.54. Defendant Gino Duguay, claims be an Property Recovery agent employee of HomeAlone Property Management Services Limited of Nova Scotia. Defendant Gino Duguayclaims by affidavit to have acted on the 29 Marshall Street and 31 Marshall Street,Fredericton, New Brunswick duplex property, claiming to do so on behalf of The RoyalBank of Canada

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55. Defendant Home Alone Property Management Services Limited is providing workon behalf of The Royal Bank of Canada, furthermore, Agents claiming to work for HomeAlone Property Management Services Limited, in Nova Scotia have acted on the 29Marshall Street and 31 Marshall Street, Fredericton, New Brunswick duplex property,claiming to do so in behalf of The Royal Bank: of Canada.56. Defendant Hugh K. Cameron is President of Cameron Auctioneers and AppraisersLtd. of Taymouth, New Brunswick, the same Auctioneer House company commissionedby Solicitor George H.LeBlanc, to conduct the subject Mortgage Sale by Auction on July16, 2009, for Royal Bank of Canada, Vendor of a Mortgage registered against subjectresidential duplex property, bearing civic address 29 Marshall Street and 31 MarshallStreet, Fredericton, New Brunswick on July 16,2009.57. Defendant Hugh K. Cameron is a 'part time' Process Server who claims to haveprovided Court Document Process Service a 'NOTICE' to the 29 Marshall Street,Fredericton, New Brunswick duplex property on July 16, 2001.58. Defendant Hugh K. Cameron is father and employer of daughter Defendant SuellenRoss who was the acting as Auctioneer at the 'Power of Sale' Auction of a Mortgage July16,2009.59. Defendant Hugh K. Cameron is father to son Defendant Hugh 1.Cameron furtherwho acting as agent for his client became the tentative purchaser of the offered'Mortgagee Deed' by a successful bid at the July 16, 2009 Auction, incidentally biddingon behalf of 5013 76 N.B. Ltd. a body corporate to purchase the 'Mortgage' registeredagainst 29 Marshall Street, Fredericton, N.B. property.60. Defendant Suellen Ross was the acting Auctioneer at the


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2009. Defendant Cox & Palmer was allegedly asked to represent the Royal Bank ofCanada and 501376 N.B. Ltd. a body corporate, ina Law suit naming Andre Murray as aDefendant, Court of Queens Bench File Number MC064209.62. Defendant Stewart McKelvey is a law fIrm inAtlantic Canada, Solicitor Hugh J.Cameron is a Partner working at the Fredericton Office. Defendant Stewart McKelveywas allegedly asked to represent 501376 N.B. Ltd. a body corporate, regarding aMortgage Sale scheduled for July 16,2009. Defendant Stewart McKelvey doesapparently allow Defendant Hugh J. Cameron to utilize their phone number and facsimilenumber so that Defendant Hugh J. Cameron may run an Auction Company from the sameOffice, that company being "Hugh 1. Cameron Company", listed at the following website'www.theauctionhouse.com ",63. Defendant Valerie Caldwell assistant to Defendant Hugh J. Cameron, did interactwith Plaintiff Andre Murray on several occasions and was charged by Defendant Hugh J.Cameron to provide a letter to 29 Marshall Street, Fredericton, New Brunswick.64. Defendant Provincial Security & Investigation Services Ltd. of Fredericton NBE3A 5G9, Canada was commissioned by RBC and 501376 N.B. Ltd. a body corporate, toact as a Process Server of Documents and Court Documents, Defendant ProvincialSecurity & Investigation Services Ltd. did allegedly dispatch Defendant Dave Daneliuka.k.a, David A. Dane1iuk to 29 Marshal Street for the alleged purpose of serving AndreMurray.65. Defendant Dave Daneliuk, is a Process Server, employed by Hugh J. Cameron,Solicitor of Record for 501376 N.B. Ltd. a body corporate, allegedly to serve documentsto the 29 Marshall Street and 31 Marshall Street, Fredericton, New Brunswick; a duplexproperty, following the July 16,2009 Mortgage Sale Auction.66. Defendant Dave Dane1iuk, is a Process Server, employed by Solicitor GeorgeLeBlanc acting for plaintiffs Royal Bank of Canada, and for 501376 N.B. Ltd. a bodycorporate to serve Court documents to the 29 Marshall Street and 31 Marshall Street,Fredericton, New Brunswick duplex property regarding Court of Queens Bench FileNumber MC064209.67. Defendant Hugh J. Cameron, is Solicitor of Record for 501376 N.B. Ltd. a bodycorporate. July 16,2009, Defendant Hugh 1. Cameron did attend the subject MortgageSale Auction, acting as a purchasing agent for 501376 N.B. Ltd. a body corporate.Defendant Hugh J. Cameron became the tentative purchaser of the offered 'Mortgage' asuccessful bidder at the July 16,2009 Auction, bidding on behalf of501376 N.B. Ltd. abody corporate to purchase the "Mortgage' registered against Betty Rose Danielski'sMarshall Street property, in Fredericton, N.B. as offered by Vendor Royal Bank: ofCanada. Solicitor Hugh 1. Cameron happens to be the Registered Secretary for theIncorporated Auctioneer House, "Cameron Auctioneers and Appraisers Ltd.", the sameIncorporated Auctioneer House of which his Father Hugh K. Cameron is President andhis sister Suellen Ross/Cameron who was acting as auctioneer the day of July 16, 2009

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Auction, furthermore, sister Suellen Ross/Cameron had just sold to brother DefendantSolicitor Hugh J. Cameron the subject Mortgage. Defendant Solicitor Hugh J. Cameron isa business partner with Defendant Richard McGuigan P.Eng and at other times acts ascouncil for Defendant Richard McGuigan P.Eng.68. Defendant Candy LeBlanc is Assistant to Partner at Cox &Palmer, MonctonSolicitor George H. LeBlanc. Defendant Candy LeBlanc claims to have sent a Notice ofMortgage Sale to Plaintiff Andre Murray at 29 Marshall Street, Fredericton by registeredCanada Post mail, which Plaintiff Andre Murray was not notified of, and consequentlythe package was returned to Defendant Candy LeBlanc as unclaimed although CandyLeBlanc would erroneously declare inan Sworn Affidavit the subject Canada PostNOTICE was refused.69. Defendant George H. LeBlanc, did act as Solicitor of Record for Vendor RoyalBank of Canada, offer by way of the 'Power of Sale' and subsequent Auction of theinvestment instrument 'Mortgage' registered to or against subject to the 29 MarshallStreet and 31 Marshall Street, Fredericton, New Brunswick duplex property. DefendantGeorge H. LeBlanc subsequently did relative to subject herewithin mentioned 'Power ofSale' and subsequent Auction of the investment instrument 'Mortgage' act as Solicitor ofRecord for the Royal Bank of Canada and 501376 N.B. Ltd. a body corporate in a jointaction to vacate Plaintiff Andre Murray from 29 Marshall Street, Fredericton, Court ofQueens Bench File Number MC064209.70. Defendant Royal Bank of Canada is the alleged Mortgagee, pursuant to an allegedMortgage granted from Betty Rose Danielski to the Royal Bank of Canada, which wasallegedly dated October 26,2000.71. Defendant Stephen J. Hill is an Associate at Cox & Palmer, Fredericton, who didattend the subject July 16, 2009 Mortgage Sale by Auction of a mortgage registeredagainst 29 Marshall Street and 31 Marshall Street, Fredericton, New Brunswick duplexproperty as agent for George H. LeBlanc agent for Royal Bank of Canada72. Defendant Atlantic Document Service Ltd. of Riverview, New Brunswick, wasallegedly commissioned or hired by Solicitor George Leblanc for Royal Bank of Canadaand for 501376 N.B. Ltd. a body corporate, to cause Service of Court Documents (Courtof Queens Bench File Number MC064209), upon Andre Murray (Defendant in thatMatter) at 29 Marshall Street Fredericton, New Brunswick. Defendant Atlantic DocumentService Ltd. Who did allegedly October 6, 2009 cause to forward the Court of QueensBench File Number MC064209 documents, by way of Acadian Lines Ltd., (a member ofGroupe Orleans Express Inc.), Package Shipment Service to Dave Daneliuk, a.k.a. DavidA. Daneliuk, of Defendant Provincial Security & Investigation Services Ltd., for CourtDocument Process Service.73. Defendant Julie Ruggiero, is a Collections Associate for Royal Bank of Canada.

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74. Defendant Julie Ruggiero, despite knowledge of, as advised by Solicitor GeorgeLeblanc, of the existing Residential Tenancy and the evident Leasehold of29 MarshallStreet by Plaintiff Andre Murray, Julie Ruggiero did regardless of these significantprejudicial, aforementioned details, did instruct Solicitor George Leblanc to obtain aCourt Order on behalf of Royal Bank of Canada, that Andre Murray and lo r otheroccupants oftbe property be required to vacate 29 Marshall Street Frederictonfu~mth. ,75. Defendant Andreen Tranchell, is a Property Management Coordinator withCentract Real Property Recovery Services, believed to be retained by Julie RuggieroCollections Associate for Royal Bank of Canada.76. Defendant Andreen Tranchell, is a Property Management Coordinator employeddirectly or indirectly by Royal Bank of Canada.77. Defendant Andreen Tranchell is believed to have retained ARA FrederictonAppraisal Associates Ltd on behalf of RBC, to appraise the 29 Marshall Street,Fredericton, property.78. Defendant, The City of Fredericton, N.B. Canada has a department called TheFredericton Police Force. On October 23,2009, The Fredericton Police Force did send 3Fredericton Police Force members to the 29 Marshall Street Fredericton, NewBrunswick.79. Defendant, FREDERICTON POLICE FORCE, did dispatch three members ofFREDERICTON POLICE FORCE to attend on the 23rd day of October 2009, eviction ofAndre Murray from his Residential Leasehold, therefore, Andre Murray's lawful andlegal occupancy as a Residential Tenant of 29 Marshall Street, Fredericton. The herewithin, aforementioned three members of FREDERICTON POLICE FORCEsubsequentially, witnessed and with knowledge of one's own mental operations or actionsparticipated inthe illegal and unlawful eviction of Plaintiff Andre Murray from his lawfuland legal Residential Leasehold occupancy of 31 Marshall Street, Fredericton by Breakand Enter including a subsequent illegal without Court "Ordered warrant to search saidpremises that being the private residence of Andre Murray _80. Defendant Barry MacKnight has vicarious liability as Chief of Police for the actsand or omissions of employees who were dispatched by FREDERICTON POLICEFORCE that being three Members of FREDERICTON POLICE FORCE who were sentto attend the residential duplex located at 29 - 31 Marshall Street, Fredericton on the 23rdday of October 2009, with the express reason (as found stated on a Court Order foreviction of Andre Murray from his lawful Residential Leasehold occupancy of 29Marshall Street, Fredericton. The herewithin, mentioned members of FREDERICTONPOLICE FORCE subsequentially, upon arriving at the Subject residential duplex atMarshall Street, Fredericton, witnessed and with knowledge of one's own mentaloperations or actions participated in the illegal and unlawful BREAK &ENTER of said31 Marshall Street premises thereby assaulted then battered Plaintiff Andre Murray as

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they (subject Police member) did ouster Plaintiff Andre Murray from his lawful and legalResidential Leasehold and occupancy of 31 Marshall Street, Fredericton.81. Defendant D. Beck a Police Constable member of FREDERICTON POLICEFORCE. attended the duplex located at 29 Marshall Street and 31 Marshall Street in theCity of Fredericton, on the 23rd day of October 2009, witnessed and with knowledge ofone's own mental operations or actions participated in the illegal and unlawful eviction ofPlaintiff Andre Murray from his lawful and legal Residential Leasehold occupancy of 31Marshall Street, Fredericton. Defendant Constable DoBeck did unreasonably and withoutauthority conduct a search through private belongings of Andre Murray at the Duplex 29Marshall Street and 31 Marshall Street property.82. Defendant Constable A. Yerxa, a member of the FREDERICTON POLICEFORCE, attended the duplex located at 29 Marshall Street and 31 Marshall Street in theCity of Fredericton, on the 23rd day of October 2009, witnessed and with knowledge ofone's own mental operations or actions participated in the illegal and unlawful eviction ofPlaintiff Andre Murray from his lawful and legal Residential Leasehold occupancy of 31Marshall Street, Fredericton. Defendant Constable A. Yerxa did unreasonably andwithout authority conduct a search through private belongings of Andre Murray at theDuplex 29 Marshall Street and 31 Marshall Street property.83. Defendant Constable C. Haines, a member of the FREDERICTON POLICEFORCE, attended the duplex located at 29 Marshall Street and 31 Marshall Street in theCity of Fredericton, on the 23rd day of October 2009, witnessed and with knowledge ofone's own mental operations or actions participated in the illegal and unlawful eviction ofPlaintiff Andre Murray from his lawful and legal Residential Leasehold occupancy of 31Marshall Street, Fredericton. Defendant Constable CoHaines did unreasonably andwithout legal authority conduct a room to room search including opening and oraccessing furniture thereby searching through private belongings of Andre Murray atboth the Duplex 29 Marshall Street and 31 Marshall Street property.84. Defendant, Justice and Consumer Affairs is a department of the New BrunswickGovernment, did dispatch two Deputy Sheriffs to attend on the 23rd day of October 2009,eviction of Andre Murray from lawful Residential Leasehold occupancy of29 MarshallStreet, Fredericton. The herewithin, aforementioned two Deputy Sheriffs subsequentially,witnessed and with knowledge of one's own mental operations or actions participated inthe illegal and unlawful eviction of Plaintiff Andre Murray from his lawful and legalResidential Leasehold occupancy of 31 Marshall Street, Fredericton.85. Defendant, Fredericton Sheriff Services, is a Office under the Justice and ConsumerAffairs department, who did on the 23rd day of October 2009, dispatch two DeputySheriffs to attend and enforce a Ex parte issued Court Order Dated Octoher 20, 2009 (ofQueens Bench Moncton Trial Division, Signed by Honorable Justice Zoel R. Dionne)that Ordered the vacating of Andre Murray, from his Residential Leasehold Occupancy,of 29 Marshall Street, Fredericton .. The here within, aforementioned two Deputy Sheriffssubsequentially, witnessed and with knowledge of one's own mental operations or actions

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participated in the illegal and unlawful eviction of Plaintiff Andre Murray from his lawfuland legal Residential Leasehold Tenant occupancy of 31 Marshall Street, Fredericton.86. Defendant KEITH F. BALL is Sheriff of the (Fredericton Regional Office) SheriffsDepartment, of Justice and Corporate Affairs, who did cause to be dispatched theherewithin mentioned subject Deputy Sheriffs to attend and enforce the subject CourtOrder Dated October 20, 2009 (of Queens Bench Moncton Trial Division, signed byHonourable Justice Zoe! R. Dionne) that Ordered the Eviction of Andre Murray from hisResidential Leasehold Occupancy of 29 Marshall Street, Fredericton.87. Defendant KEITH F. BALL did October 23,2009 dispatch Deputy SheriffCLARENCE MORENCY and Deputy Sheriff DALE G. KOZAK with instructions toassemble with three members of FREDERICTON POLICE FORCE, to enforce a CourtOrder of October 20, 2009 (of Queens Bench Moncton Trial Division, signed byHonorable Justice Zoel R. Dionne) reasonably, Ordering Andre Murray to vacate fromhis Residential Leasehold Tenant Occupancy of29 Marshall Street, Fredericton.88. Defendant Deputy Sheriff CLARENCE MORENCY of the Fredericton, SheriffsServices attended 31 Marshall Street on the 23rd day of October 2009, witnessed andparticipated inthe illegal and unlawful break and enter immediately followed by Ousterof Plaintiff Andre Murray.89. Defendant Deputy Sheriff DALE G. KOZAK of the Fredericton, Sheriffs Servicesattended 31 Marshall Street on the 23rd day of October 2009, witnessed and participatedin the illegal and unlawful break and enter immediately followed by Ouster of PlaintiffAndre Murray.90. Defendant ARA Fredericton Appraisal Associates Ltd., did dispatch and or assignagent Defendant John Carter to provide an appraisal of 29 and 31 Marshall Street,Fredericton, property.91. Defendant D. Harold Moore, ina vicarious manner, inthis case, through a legalsubstitute is liable (vicarious liability) as President of ARA Fredericton AppraisalAssociates Ltd office located at 102-3 Main Street, Fredericton, New Brunswick, E3A9N6.92. Defendant Peter E. Atkinson, ina vicarious manner, in this case, through a legalsubstitute is liable (vicarious liability) as Defendant Peter E. Atkinson is employed in amanagerial position by and for ARA Fredericton Appraisal Associates Ltd 102-3 MainStreet, Fredericton, New Brunswick. E3A 9N6.93. Defendant John Carter is a property appraiser employed by ARA FrederictonAppraisal Associates Ltd. who was dispatched and or assigned to provide an appraisal ofthe Residential Duplex 29 and 31 Marshall Street, Fredericton property, November 9,2009.

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94. Defendant Centract Real Property Recovery Services of Toronto, Ontario providesProperty Recovery Services in a vicarious manner, in this case, through a legal substituteis liable (vicarious liability) therfore allegedly commissioned Defendant Home AloneProperty Management Services Limited to provide work on behalf of Royal Bank ofCanada to the 29 Marshall Street, Fredericton property.95. Defendant Richard McGuigan P.Eng, is President of MECCA Corporation,owner/director of 501376 N.B. Ltd. a body corporate, of which the latter is a tentativepurchaser of the 'Mortgage' which was offered by Auction a 'Power of Sale' pursuant tothe New Brunswick Property Act. Subject Mortgage Sale Auction was held on July 16,2009 furthermore, herein before mentioned Solicitor Defendant Hugh J. Cameron was tilepurchasing agent acting for 501376 N_B. Ltd. a body corporate., Defendant RichardMcGuigan P.Eng and Defendant Hugh J. Cameron are verily believed to be businesspartners96. Defendant Michael A. MeWilliam is a Solicitor and Partner at Cox &Palmer,Moncton office and did attend Court of Queens Bench, Trial Division Judicial District ofMoncton, on December 14,2009 as Agent for Cox & Palmer, in the absence of SolicitorGeorge H _ LeBlanc_97_ Defendant Edwin G_(Ted) Ehrhardt, Q.C. Partner at Bingham Law Moncton(Bingham Robinson Macl.ennan Ehrhardt Teed), did on several occasions thereforescheduled Court Hearings did attend Court of Queens Bench, Trial Division JudicialDistrict of Moncton, as Agent for Solicitor George H.LeBlanc.98. Defendant Danah Smith is a Litigation Paralegal at Bingham RobinsonMacLennan Ehrhardt Teed and working with Defendant Edwin G_(Ted) Ehrhardt didcorrespond and did send various documents to Plaintiff Andre Murra y on DefendantEdwin G. (Ted) Ehrhardt therefore on behalf of and in George H. Leblanc's stead.99. Defendant Bev McAffee Legal Assistant to Edwin (Ted) Ehrhardt, Q_C . BinghamRobinson MacLennan Ehrhardt Teed and working with Defendant Edwin G. (Ted)Ehrhardt did correspond and did send various documents to Plaintiff Andre Murray onDefendant Edwin G. (Ted) Ehrhardt on behalf of and inGeorge H. LeBlanc's stead.100. Defendant Bingham Robinson MacLennan Ehrhardt Teed, 95 Foundry Street,Suite 300, Moncton, New Brunswick, Canada, EIC 5H7101. Defendant Neil Rodgers,15 Fisher Ave, Fredericton, New Brunswick, E3A 4J1didprovide erroneous affidavit which was used as evidence against Plaintiff Andre Murray.102. Defendant Brian Parker, 27 Marshall Street, Fredericton, New Brunswick, E3A 4J8 didsteal sensitive Legal Documents and generally various correspondences from Plaintiff AndreMurray's mailbox inter alia.

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103. Defendant Ghislain Bernard, 231 Champlain St-Suite 100, Dieppe, NewBrunswick, EIA IN9. provide erroneous affidavit which was used as evidence againstPlaintiff Andre Murray104. Defendant Gary Steele, 651 Loyalist Crt, Fredericton, New Brunswick E3B 3K9provide erroneous affidavit which was used as evidence against Plaintiff Andre Murray105. Defendant 501376 N.B. Ltd. a body corporate,2l! Doak Road, Fredericton, NBE3C 2E6 tentative purchaser of the 'Mortgage' which was offered by Auction a 'Powerof Sale' pursuant to the New Brunswick Property Act. Subject Mortgage Sale Auctionwas held on July 16, 2009 furthermore, herein before mentioned Solicitor DefendantHugh J. Cameron was the purchasing agent acting for 501376 N.B. Ltd. a bodycorporate,. Defendant Richard McGuigan P.Eng and Defendant Hugh 1.Cameron areverily believed to be business partners

(2.) The place of residence of the plaintiff.The PlaintiffANDRE MURRAYAddress for service within New Brunswick:31 Marshall StreetFredericton, N.B.E3A4J8

(4.) Each allegation of a material fact relied upon to substantiatethe claim.

106. Plaintiff Andre Murray, year 2005 signed a Residential Leasehold Tenancyagreement inpursuance with New Brunswick Residential Tenancy Act, reasonably toestablish his Tenancy for each of the residential units located within the residentialduplex civic addresses 29 Marshall Street and 31 Marshall Street, inthe City ofFredericton, New Brunswick, therefore, Plaintiff Andre Murray having acquired theResidential Leasehold Tenancy agreement according to the Residential Tenancies Act ofNew Brunswick Plaintiff Andre Murray is guaranteed legal shelter and or protectionfrom all other Acts, moreover, and consequently by the laws found therewithin, saidResidential Tenancies Act., Plaintiff Andre Murray is therefore (in this case) guaranteedprotection from eviction. Advance rental payments where made, for both Duplex address29 Marshall Street and 31 Marshall Street, Fredericton, New Brunswick. Plaintiff AndreMurray had not breached any condition of the Lease, was not inarrears regarding rentalpayments, never was and is currently not in default of the Lease agreement, moreover,has since remained in good standing according to the standards established as legislatedlaw inNEW BRUNSWICK and pursuant to the NOTWITHSTANDING all other Actsclause, found therewithin, subject Residential Tenancies Act.

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107. July 16,2009, a Mortgage Sale by Auction was held without Notice to PlaintiffAndre Murray despite his registered CONSTRUCTIVE NOTICE found at Service NewBrunswick Land Titles Office furthermore, registered against same title as that whichsubject Mortgage was granted. consequently Plaintiff Andre Murray was not inattendance and naturally did not have the opportunity to bid.108. Plaintiff Andre Murray at that time did and continues to have a registered $80,000Lien at Service New Brunswick Land Titles Office in pursuance with the Mechanic'sLien act of New Brunswick, moreover, subject improvements/renovations had started onthe Marshall Street Duplex property year 2005 regarding contracted materials, labour andservices rendered for the benefit of the Title and Title Holder Betty Rose Danielski.109. On October 20,2009, in Court of Queen's Bench Moncton Trial Division, anMotion was heard Ex Parte, without notice to(Defendant in that matter) Andre Murray,furthermore, the subject Motion was requesting ORDERS Of EVICTION effectively tovacate the occupant(s) as the case may be, from 29 Marshal Street Fredericton, NewBrunswick. The Order as requested at the hearing of subject Motion was granted, theORDER was drafted by Solicitor George H. LeBlanc, who knowingly inter alia involvingfraudulent representations caused the Order to be signed by the Mr Justice same day asthe Hearing of the matter before the Honorable Court October 20, 2009.110. On October 23,2009, without prior Notice, Plaintiff Andre Murray was physicallyand forcefully evicted (against Andre Murray's adamant objections) from his residence31 Marshall Street, Fredericton, New Brunswick; of special interest to this HonorableCourt must be the fact that this eviction of Plaintiff Andre Murray was occurring, despitethe fact that 31 Marshall Street, is not an address specified in the COURT OF QUEENSBENCH Moncton TRIAL DIVISION EVICTION ORDER of October 20,2009,nevertheless, two members of Fredericton, Sheriff Services (Regional Office) :

(I) Deputy Sheriff Clarence Morency(2) Deputy Sheriff. Defendant Dale G. Kozak

accompanied by three members of FREDERICTON POLICE FORCE:(1) Defendant Constable D. Beck,(2) Defendant Constable A. Yerxa,(3) Defendant Constable C. Haines

and one Property Recovery Agent:(1) Gino Duguaycommissioned by RB.C. (who's capacity is not certain) all of the herewithin namedparties collaborated in said subject eviction of Andre Murray from 31 Marshall Street,

Fredericton, New Brunswick111. On Date October 23,2009, Plaintiff Andre Murray having just suffered a illegaland unlawful "Break and Entry' of his 31 Marshall Street residence, subsequently

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suffered forceful physical removal from said premises, further, under threat of force, wasprohibited from re-entering his Residential leasehold residence of 31 Marshall Street;please note: Plaintiff Andre Murray while at 31 Marshall Street the subject Court Orderto evict Plaintiff Andre Murray from 29 Marshall Street, Fredericton, New Brunswickhad been provided for his inspection; of special interest to this Honorable Court may bethe fact that COURT oftirst instance therefore ORDERING the eviction of PlaintiffAndre Murray from his 29 Marshall Street residence could never have intended that thesubject ORDER would be enforced in such a manner as to be transgressing reasonablebounds commonly considered grossly offensive to the sense of right or decency, as AndreMurray was not allowed to remove his personal belongings from his 29 Marshall Streetresidence of (at that time) four years; moreover, tenant Andre Murray was not permittedto remove his personal property from the said premises; October 20,2009, two membersof Fredericton, Sheriff Services (Regional Office ): Deputy Sheriff Clarence Morencyand Deputy Sheriff, Defendant Dale G. Kozak accompanied by three members ofFREDERICTON POLICE FORCE: Defendant Constable D. Beck, Defendant ConstableA. Yerxa, and Defendant Constable C. Haines and one Gino Duguay commissioned byKB.C. (who's capacity is not certain) all of the herewithin named parties collaborated insaid subject eviction of Andre Murray from 29 Marshall Street, Fredericton, NewBrunswick.(5.) The plaintiff's claim.The Plaintiff's Claim includes the following.Defendant Betty Rose Danielski112. Defendant Betty Rose Danielski, Landlord did Breach the Covenant of quietenjoyment, by consenting to and encouraging tortious actions, therefore, interfering withthe use and enjoyment of the leased premises, that, which is substantial and of grave andpermanent nature, such, that it constitutes a serious interference with the ability of theTenant Plaintiff Andre Murray to exercise right of possession of his ResidentialLeasehold Tenancy at 31 Marshall Street Fredericton, New Brunswick113. Defendant Betty Rose Danielski, as Landlord did Breach the Covenant of quietenjoyment, by consenting to and encouraging tortious actions, therefore, interfering withthe use and enjoyment of the leased premises, that, which is substantial and of a graveand permanent nature such that it constitutes a serious interference with the ability of theTenant Plaintiff Andre Murray to exercise right of possession of his ResidentialLeasehold Tenancy at 29 Marshall Street Fredericton, New Brunswick.

114. Defendant Betty Rose Danielski, regarding the lawful and legal Tenancy ofPlaintiff Andre Murray did misrepresent details by obfuscation and allusions beingerroneous misrepresentation of the facts, as can be found in various sworn affidavits andvarious correspondence.

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115. Defendant Betty Rose Danielski, by her consent and active creative encouragementinstigated the illegal and unlawful eviction of Plaintiff Andre Murray from hisResidential Leasehold Tenancy at 31 Marshall Street property, Fredericton, NewBrunswick.116. Defendant Betty Rose Danielski, by her consent and active creative encouragementinstigated the illegal and unlawful eviction of Plaintiff Andre Murray from hisResidential Leasehold Tenancy at 29 Marshall Street property, Fredericton, NewBrunswick.117. Defendant Betty Rose Danielski, acting as a famacide, therefore a defamer and orslanderer did cast aspersions on Plaintiff Andre Murray effectively blackening PlaintiffAndre Murray's name. There is ample evidence of the negative consequences of theslander practiced against Plaintiff Andre Murray by offender Defendant Betty RoseDanielski. There exists throughout the entire course of this matter, unrelenting tones,denoting despair, statements that makes a claim, expressly stated or implied to be factual,which unrelentingly arises where Defendant Betty Rose Danilski reveals erroneousinformation about Plaintiff Andre Murray that could never be relevant to the mattersbefore this Court, and the release of that, which would offend a reasonable person. Thefollowing are all attempts to cast a false light that, which may destroy another's reputationand does constitute libel intended to affect the plaintiffs mental or emotional well-being.118. Defendant Betty Rose Danielski, in a vicarious manner, inthis case, through a legalsubstitute is liable (vicarious liability) for the Tenancy Contracts signed on behalf ofDefendant Betty Rose Danielski, by her (as assigned by Betty Rose Danielski) in thiscase a CONTINUING POWER OF ATTORNEY FOR PROPERTY Richard Boileau,therefore, consequently as earlier stated, resulted in the subject, Residential leaseholdTenancy Contracts being signed, therefore, leased the 29 Marshall Street and or 31Marshall Street property, Fredericton, New Brunswick to Andre Murray in the year 2005.Defendant Richard Boileau119. Defendant Richard Boileau, appointed CONTINUING POWER OF ATIORNEYFOR PROPERTY, on behalf of and for Betty Rose Danieslki did sign legally bindingcontracts on behalf of Defendant Betty Rose Danielski. Those contracts still stand andhave full legal affect.Defendant Robert C. Jones

120. Defendant Robert C. Jones as director of Home Alone Property ManagementServices Limited in a vicarious manner, in this case, through a legal substitute is liable(vicarious liability) for the actions of the aforementioned company and agents acting onbehalf of subject company, while doing business as Home Alone Property ManagementServices Limited, inthe year 2009 and following years.

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121.. J:iome A~one Property Management Services Limited, of Nova Scotia claims to bepr~vldmg services to Royal Bank of Canada, therefore agents claiming to be employedby and or work for Home Alone Property Management Services Limited, have acted inthe year 2009 and following years on the 29 Marshall Street and 31 Marshall StreetFredericton, New Brunswick duplex property, therefore claiming to be performing onbehalf of Royal Bank of Canada.122.. Defe?-d~nt ~obert C. Jones as director of Home Alone Property ManagementServices Limited IIIa vicarious manner, in this case, through a legal substitute is liable(vicarious liability) for the actions of Agents acting for Home Alone PropertyManagement Services Limited, whom in the year 2009 and following years, attendedsubject property at 29-31 Marshall Street Fredericton N.B.Defendant Gino Duguay123. Defendant Gino Duguay, calls himself a Property Recovery Agent employedtherefore by Home Alone which was and or is contracted in the year 2009 and followingyears (directly or indirectly) by Royal Bank of Canada.124. Defendant Gino Duguay did attend 31 Marshall Street and 29 Marshall Streetrespectively on the 23rd day of October 2009, witnessed and participated in the illegaland unlawful tortuous Break and Enter eviction of 31 Marshall Street, Fredericton, NewBrunswick, a duplex property, therefore witnessed and participated as Plaintiff AndreMurray respectively was ousted from 31 Marshall Street then evicted from 29 MarshallStreet in the City of Fredericton.125. Defendant Gino Duguay, on the 23rd day of October 2009, participated in theillegal and unlawful tortuous Break: and Enter eviction of 31 Marshall Street, Fredericton,New Brunswick did illegally and forcibly enter into the home of Plaintiff Andre Murrayat 31 Marshall Street, Fredericton, by actually breaking the doorknob, and destroying theprimary lock and mechanism within the door, a secondly security system existed whichwas over come by Defendant Gino Duguay by forcing the system to fail as DefendantGino Duguay and others used their bodies to ram the steel door open, thereby using greatforce causing excessive damage. Defendant Gino Duguay had a duty of care to ensurethat he was acting on the correct address, Defendant Gino Duguay was Negligent in thatduty, by breaking down an entrance door at the address not specified in the Court Orderfor eviction.]26. Defendant Gino Duguay did subsequently proceed to trespass into the privateLeasehold Residence of Plaintiff Andre Murray, at 31 Marshall Street, Fredericton.Defendant Gino Duguay wrongfully interferedwith the Plaintiff Andre Murray's peacefulpossession and quiet enjoyment of his Leasehold Residence at 31 Marshall Street,Fredericton, without color of legal or lawful right moreover, under protest and withoutconsent / permission of the Leaseholder Plaintiff Andre Murray furthermore, against theobjections of Plaintiff Andre Murray.

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127. Defendan~ Gino Dug~ay did unreasonably and without legal or lawful authority,change the locking mecharusms of all the access doors to Plaintiff Andre MurrayResidential Home 31 Marshall Street.128. Defendant Gino Duguay did invade the privacy and invade the residential home ofPla~nt~ffAndre Murray. Moreover, having been previously informed (same day) byPlaintiff Andre Murray, who painstakingly articulated and produced, therefore, revealed aDocument bearing the substance of a legal Agreement that being a Year to Year,Residential Leasehold Tenancy agreement for 31 Marshall Street; the followingResidential Leasehold Tenancy documentation was offered for all in attendance toexamine including Defendant Gino Duguay, however, after Plaintiff Andre Murray hadbeen made abundantly clear to Defendant Gino Duguay, both verbally therefore, October23,2009 provided Residential Leasehold Tenancy documentation, despite the following,acts of due diligence on behalf of Plaintiff Andre Murray November 18, 2009 atapproximately 7 pm Defendant Gino Duguay and an associate of his where discoveredtrespassing in the dining room of 31 Marshall Street. Both Defendant Gino Duguay andhis associate where acting upset as they hastily departed 31 Marshall Street area entirelyin two separate non company vehicles (one was a truck the other a car). This was not thefirst or last time that Plaintiff Andre Murray verbally NOTICED 'Cease and Desist' ofDefendant Gino Duguay, and or Defendant Gino Duguay's son who would randomlyvisited 31 Marshall Street property alone and or with his adolescent friends;this subject harassment continued as Gino Duguay would not stop intruding uponPlaintiff Andre Murray's seclusion, solitude, and into Plaintiff Andre Murray's privateaffairs, by continuously attempting to enter the subject 31 Marshall Street propertywithout permission of the Leaseholder Plaintiff Andre Murray and without lawfulauthority.129. Defendant Gino Duguay did fraudulently provide information to the Court ofQueens Bench, Moncton Trial Division, as can be found within a sworn affidavit to theCourt Dated February 25,2010, which deceives the Honorable Court into believing thatDefendant Gino Duguay had taken pictures of the entire duplex including both separateresidences 31 Marshall Street and 29 Marshall Street Fredericton, on October 23, 2009and two days later October 25,2009. Defendant Gino Duguay alleged to have takenphotos on two different days that he had in fact had not taken,130. Defendant Gino Duguay did boldly slander Plaintiff Andre Murray'S reputation byalluding to illicit and illegal activity occurring on or around the Marshall Street propertythis slander was spoken to an acquaintance of Plaintiff Andre Murray, while DefendantGino Duguay was discovered by this same witness acquaintance of Plaintiff AndreMurray lurking about the Marshall Street property.Defendant Home Alone Property Management Services Limited131. Defendant Home Alone Property Management Services Limited allegedly providesProperty Management Services for Royal Bank of Canada.

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132. Defendant Home Alone Property Management Services Limited is providingServices, allegedly at the request of Centract Real Property Recovery Services allegedlyon behalf of Mortgagee Royal Bank of Canada.133. Defendant Home Alone Property Management Services Limited; in a vicariousmanner, in this case, through a legal substitute is liable (vicarious liability) for thesubsequent illegal tortious actions, consequences, of the actions of Defendant GinoDuguay and any other agents acting on Home Alone Property Management ServicesLimited's behalf against Plaintiff Andre Murray at his legal and lawful ResidentialTenancy Leasehold and occupancy of31 Marshall Street, Fredericton.Defendant Hugh K. Cameron134. Defendant Hugh K. Cameron is a Director of Cameron Auctioneers and AppraisersLtd. 857 Rte. 8 Hwy, Taymouth, New Brunswick, E6C 2B5.

135. Defendant Hugh K. Cameron, as Director of Cameron Auctioneers and AppraisersLtd. was negligent by allowing daughter Defendant Suellen Ross (Cameron) to be theAuctioneer at the subject 'Power of Sale' Mortgage Sale offered at Auction Sale of July16,2009, when Defendant Hugh K. Cameron's son Defendant Hugh J. Cameron wasacting as purchasing agent and bidding on behalf of his client, 501376 N.B. Ltd. a bodycorporate and who was at the same time Secretary of this very same company CameronAuctioneers and Appraisers Ltd.136. Defendant Hugh K. Cameron was negligent in not avoiding the reasonableapprehension of bias associated with such a blatant conflict of interest.137. Defendant Hugh K. Cameron has had his Auctioneer license renewed by StewartMcKelvey, the very same law firm that his son, Solicitor Hugh J. Cameron is a partner.Defendant Suellen Ross138. Defendant Suellen Ross, maiden family name Cameron, was the Auctioneer at thesubject 'Power of Sale' Mortgagee Deed offered at Auction Sale of July 16,2009.139. Defendant Suellen Ross is the daughter of Auctioneer Hugh K. Cameron (the fatherof Solicitor Hugh J. Cameron).140. Defendant Suellen Ross is a Auctioneer employed by Cameron Auctioneers andAppraisers of Taymouth, New Brunswick, which is owned by her father and AuctioneerHugh K. Cameron.141. Defendant Suellen Ross has had her Auctioneer license renewed by the very samelaw firm her brother Solicitor Hugh J. Cameron is a partner of, Stewart McKelvey.

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142. Defendant Suellen Ross owed a duty of care by another, to ensure that they do notsuffer any unreasonable harm or loss. If such a duty is found to be breached, a legalliability is imposed upon the duty owed, to compensate the victim for any losses theyincur. Defendant Suellen Ross prior to July 16, 2009, having been advised that aMechanics Lien is Registered with Government ofNB Land Titles Office against subjectproperty, of which as a Registered and licensed Auctioneer existed a duty to ensure a fairequitable price. Negligence occurred as a result of not attempting to ensure equityredemption on behalf of the Lien Claimant of the here within before mentionedMechanics Lien that being Plaintiff Andre Murray.143. Defendant Suellen Ross did (fraudulently) certify that the subject Mortgage SaleAuction was conducted by her in a fair, open and proper manner and according to thebest of her skill and judgement. Defendant Suellen did not remove herself from apparentconflict of interest, and reasonable apprehension of bias by selling to her brotherDefendant Hugh J. Cameron, a secretary of the very same company CameronAuctioneers and Appraisers Ltd, who employs Defendant Suellen Ross, bidding at thesubject auction.144. Defendant Suellen Ross/Cameron as acting Auctioneer sold a Mortgage at auctionJuly 16,2009 to the Secretary of the Company she works for Cameron Auctioneers andAppraisers Ltd controlled and run by her father and brother, furthermore, DefendantSuellen Ross/Cameron's brother is her boss and was the successful bidder ofthe subjectMortgage July 16, 2009 which likely explains the reason for an unlikely final biddingfigure and total which ended with] dollar as $79,101.Defendant Cox & Palmer145. Defendant Cox & Palmer and partners in a vicarious manner, in this case, through alegal substitute is liable (vicarious liability) for the actions resulting in damages and orharm caused by any and all parties who may have been employed by Defendant Cox &Palmer or caused to be employed between the year 2009 by Defendant Cox & Palmerresulting in contact directly or indirectly with Plaintiff Andre Murray as found currentlynamed herewithin and or as may be named in the future until the end of this subjectmatter of a Notice of Action with statement of Claim find remedy at Law throughlitigation and or discovery and out of Court settlement as the case may be.Defendant Stewart McKelvey146. Defendant Stewart McKelvey and the other partners of the Stewart McKelvey LawFirm in a vicarious manner, in this case, through a legal substitute is liable (vicariousliability) for the actions resulting in damages and or harm caused by any and all partieswho may have been employed by Defendant Cox &Palmer or caused to be employedbetween the year 2009 by Defendant Cox & Palmer resulting in contact directly orindirectly with Plaintiff Andre Murray as found currently named herewithin subjectAction and Of as may be named in future Actions and or Amendments of same Action

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until the end of this subject matter of a Statement of Claim finds remedy at Law throughlitigation and or discovery and or out of Court settlement as the case may be.

147. Defendant Valerie Caldwell, was Negligent and had a Duty of Care to ensure thatas assistant to Defendant Hugh 1. Cameron Solicitor of Record for 501376 N.B. Ltd. abody corporate, she must take reasonable care to avoid acts or omissions whichDefendant Valerie Caldwell can reasonably foresee, would be likely to cause injury to theRoyal Bank of Canada, 501376 N.B. Ltd. a body corporate or to the Plaintiff AndreMurray, namely as in this case not applying reasonable effort in informing PlaintiffAndre Murray of the upcoming Mortgage Sale which Plaintiff Andre Murray holds a$80,000 Mechanics Lien on the subject Property, so that Plaintiff Andre Murray couldattend the Mortgage Auction and with all fairness have an opportunity to bid on thesubject property.148. Defendant Valerie Caldwell, was Negligent and had a Duty of Care to ensure thatas assistant to Defendant Hugh 1. Cameron Solicitor of Record for 501376 N.B. Ltd. abody corporate, she must take reasonable care to avoid acts or omissions, or participate inactions supportive of Defendant Hugh 1. Cameron which Defendant Valerie Caldwell canreasonably foresee, would be likely to cause injury to Plaintiff Andre Murray.Defendant Provincial Security & Investigation Services Ltd.149. Defendant Provincial Security & Investigation Services Ltd in a vicarious manner,in this case, through a legal substitute is liable (vicarious liability) an employer is strictlyliable for torts committed by those under his command, when they are found to be hisemployees and or authority is delegated as in this case for the actions and damagescaused by Defendant Dave Daneliuk a.k.a. David A.Daneliuk, and other agents acting onDefendant Provincial Security & Investigation Services Ltd's behalf.Defendant Dave DaneIiuk a.k.a. David A. Daneliuk150. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, is a owner operator ofProvincial Security & Investigation Services Ltd. P.O. Box 3234 where he employeeshimself to act as a Process Server.151. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, is a Process Server employedwith Provincial Security & Investigation Services Ltd. P.O. Box 3234 Stn "B",Fredericton NB E3A 509, Canada. Defendant Dave Daneliuk a.k.a. David A. Daneliukhas been employed on separate occasions by various parties to this action, such as theRoyal Bank of Canada, and 501376 N.B. Ltd., a body corporate, to cause service ofOfficial Court Documents upon Plaintiff Andre Murray.152. Defendant Hugh 1. Cameron did send Defendant Dave Dane1iuk to the 29 MarshallStreet property, Fredericton, New Brunswick to personally serve Plaintiff Andre Murraythe following document from Hugh J. Cameron Dated July 17,2009 marked HandDelivered, titled "Re: 29 -3 1 Marshall Street, Fredericton, N.B."

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153. Defendant Atlantic Document Service Ltd. did send Defendant Dave Daneliuk tothe 29 Marshall Street property, Fredericton, New Brunswick to personally serve PlaintiffAndre Murray the following documents:

a. Notice of Action with Statement of Claim attached (FORM 16 A) Dated atMoncton, New Brunswick, September 17th, 2009.b. Notice of Motion (FORM 37 A) Dated at Moncton, New Brunswick,September 17th, 2009.

c. and supporting affidavit documents.154. Defendant Dave Daneliuk, is a Process Server, employed by Solicitor GeorgeLeBlanc acting for plaintiffs Royal Bank of Canada, and for 501376 N.B. Ltd. a bodycorporate to serve Court documents to the 29 Marshall Street and 31 Marshall Street,Fredericton, New Brunswick duplex property.155. Defendant Dave Daneliuk erroneously claimed to have attempted Service ofDocuments to Plaintiff Andre Murray October 5th to 10th and October 13th 2009.156. Defendant Dave Daneliuk, initially perjured himself by Sworn Affidavit. DefendantDave Daneliuk deceived the Honorable Courts and then at a later date, using a differentname and as David A. Dancliuk retracts his earlier perjured Affidavits confessing that thealleged attempts of Court Document Service found as Sworn to in his earlier Affidavitshad not actually occurred.157. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, confessed to perjuring himselfin two separate Sworn Affidavits, one Affidavit and one Affidavit of Service, both Dated:14th day of October, 2009, where he erroneously claimed to have unsuccessfully attemptedservice of the hereinbefore mentioned, Court Documents (listed in previous paragraph).mentioned documents 3 separate times on October 5,2009, by a previous Sworn AffidavitDate 14th day of October, 2009, that he had on three separate occasions attended the civicaddress 29 Marshall Street, Fredericton for the purpose of service of Court Documentsupon Andre Murray. Process Server Dave Daneliuk did not have the Court DocumentsOctober 5th, 2009 to Serve on Defendant Andre Murray as he had erroneously claimed inhis Affidavit Sworn to Dated: 14th day of October, 2009.158. Defendant Dave Daneliuk a.k.a, David A. Daneliuk, did further claim anotherfraudulently claimed Tuesday, October 6th, 2009 attempts of service, in a new Affidavitof David A. Daneliuk SWORN TO in Fredericton, NB, Dated: 14th day of October, 2009.159. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, did retract the three separatefraudulently claimed Monday, October 5th, 2009 attempts of service, in a new Affidavitof David A. Daneliuk SWORN TO in Fredericton, NB, Dated the 12th day of March,2010.160. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, did have a duty of care toserve the subject documents to Plaintiff Andre Murray according to instruction and the

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Rules of Court. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, was Negligent inthat Duty.161. Defendant Dave Daneliuk a.k.a. David A. Daneliuk, did have a duty of care toswear Affidavits which only contained the truth regarding Plaintiff Andre Murray and theaccurate details of service attempts according to instruction and the Rules of Court.Defendant Dave Daneliuk a.k.a. David A. Daneliuk, was Negligent in that Duty.162. Defendant Dave Daneliuk a.k.a, David A. Daneliuk, acting as a famacide, defamerand or slanderer did cast aspersions on Plaintiff Andre Murray effectively blackeningPlaintiff Andre Murray's name. There is ample evidence of the negative consequences ofthe famacide practiced against Plaintiff Andre Murray by offender Defendant DaveDaneliuk a.k.a. David A. Daneliuk. There exists throughout the entire course of thismatter, unrelenting tones, denoting despair, statement that makes a claim, expresslystated or implied to be factual, which unrelentingly arises where Defendant DaveDaneliuk a.k.a. David A. Daneliuk reveals information about Plaintiff Andre Murray thatis not of public concern, and the release of which would offend a reasonable person. Thefollowing are all attempts to cast a false light that may destroy another's reputation anddoes constitute libel intended to affect the plaintiffs mental or emotional well-being.Defendant Hugh J. Cameron,163. Defendant Hugh J. Cameron, is Solicitor of Record for 501376 N.B. Ltd. a bodycorporate. Defendant Hugh J. Cameron, is a partner at Stewart McKelvey, Barristers,Solicitors and Trademark Agents, office is located at Suite 600, Frederick Square, 77Westmorland Street, P.O. Box 730 Fredericton NB, E3B 5B4.164. Defendant Hugh J. Cameron, is Solicitor of Record for 501376 N.B. Ltd. a bodycorporate. Defendant Hugh J. Cameron was acting as a purchasing agent July 16, 2009.Defendant Hugh J. Cameron became the tentative purchaser ofthe offered 'MortgageeDeed' a successful bidder at the July 16,2009 Auction, bidding on behalf of501376 N.B.Ltd. a body corporate to purchase the 'Mortgagee Deed' registered against 29 MarshallStreet, Fredericton, N.R165. Defendant Hugh J. Cameron, acted as purchasing agent and did attend at the'Power of Sale' Mortgage Auction July 16,2009, successfully bidding $79,101 on behalfof 501376 N.B. Ltd. a body corporate, to purchase, as offered by the vendors RBC, aInvestment Instrument, the 'Mortgagee Deed' Registered against the subject property 29Marshall Street, Fredericton N.R, Solicitor Hugh J. Cameron's, successful bid $79,101was only $23 over the amount owed the RBC vendors.166. The successful bidder, as above mentioned, at the July 16,2009 Auction Sale of theMortgagee deed as offered by Vendor RB.C. was Solicitor Hugh J. Cameron, bidding for501376 N.B. Ltd. a body corporate. Solicitor Hugh 1. Cameron happens to be theRegistered Secretary for the Incorporated Auctioneer House the same IncorporatedAuctioneer House of which his Father Hugh K. Cameron is President and his sister

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Suellen Ross/Cameron who had just sold to him, Secretary; Hugh J. Cameron in person,the Mortgagee Deed.167. Of further interest and apparent conflict of interest is the fact that all AuctioneerLicence renewal of Suellen Ross/Cameron, Hugh K. Cameron and Secretary AuctioneerSolicitor Hugh J. Cameron are prepared at the same Law Finn Office as is the Partnershipwhich Secretary Auctioneer Solicitor Hugh J. Cameron is a partner and does practice as alawyer.168. Contact information found on public registered listings of Auctioneer Housesindicates that the same address as does Solicitor Hugh J. Cameron practice law is the Faxphone number and email contact information as is used by Solicitor Hugh J. Cameron inhis practice of law. In fact this same email address was used when correspondencebetween Solicitor Hugh J. Cameron and Plaintiff Andre Murray regarding his firmsrepresentation of the 501376 N_B. Ltd., a body corporate.169. The Plaintiff Andre Murray claims that the actions of the Defendant Hugh J. Cameronconstitute an intentional or negligent infliction ofmental harm. Defendant Hugh J. Cameron didexhibit a reckless disregard for the likelihood of causing emotional distress to PlaintiffAndre Murray. The Plaintiff Andre Murray claims that the actions of the Defendant have causedtremendous mental suffering and anguish and the Defendant Hugh J. Cameron knew or ought tohave known that its actions would cause damage to Plaintiff Andre Murray.170. Defendant Hugh J. Cameron did assault Plaintiff Andre Murray in an intentionalattempt or threat to inflict injury upon his person, utterances sufficiently articulated toallude, through the verbalised elaborated illustrations of same, the following wherecoupled with an apparent, and promised ability to cause the harm, which, has, as wasintended by Defendant Hugh J. Cameron, did purposefully, has consequently, created aconstant state of apprehension of bodily harm or offensive contact in Plaintiff AndreMurray. Defendant Hugh J. Cameron did imply that use of force would be used ifnecessary to gain entry to Plaintiff Andre Murray's residence.171. Defendant Hugh J. Cameron did intentionally interfere with contractual relationsand economic interests of Plaintiff Andre Murray. Defendant Hugh J. Cameron was awareof the Lien registered against the Marshall Street property which was regarding asubstantial amount of investment which would be lost by Plaintiff Andre Murray andproceeded to take actions which would ensure that event. By way of the Lien ClaimAction which Defendant Hugh J. Cameron was aware of by way of Certificate of Pendinglitigation, Defendant Hugh J. Cameron would have known that moving forward with thePurchase of the property would have caused further damage172. Defendant Hugh J. Cameron did cause intentional interference with contractualrelations and economic interests Plaintiff Andre Murray. Defendant Hugh J. Cameron didintend to evict Plaintiff Andre Murray despite knowledge of the fact that Plaintiff AndreMurray was a self employed Artist, in all likely hood working from home, and that theeviction would cause an economic loss to the Plaintiff Andre Murray resulting from theinterference with Plaintiff Andre Murray's method of gaining his living. Because the

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October 20th 2009 Order to vacate was achieved by a fraud upon the Court then the actwas by illegal means. Plaintiff Andre Murray did experience a loss of income directlybecause of this.173. Defendant Hugh J. Cameron was Negligent and had a Duty of Care to ensure thatDefendant Hugh J. Cameron must take reasonable care to avoid acts or omissions whichDefendant Hugh J. Cameron can reasonably foresee, would, likely, cause injury to thePlaintiff Andre Murray. Defendant Deputy Sheriff CLARENCE MORENCY andDefendant Deputy Sheriff DALE G. KOZAK were informed by Defendant Hugh J.Cameron, that despite the fact the October 20, 2009 Order only stated a 29 MarshallStreet address, Plaintiff Andre Murray should be vacated from both 29 and 31 Marshal1Street anyway. Defendant Hugh J. Cameron is liable for the damages Defendant Hugh J.Cameron have caused by wilfully disregarding a Court Order and negligently instructingothers to act without lawful authority.Defendant Candy LeBlanc174. Defendant Candy LeBlanc, was Negligent and had a Duty of Care to ensure thatas assistant to Defendant George H. LeBlanc Solicitor of Record for the Royal Bank ofCanada, she must take reasonable care to avoid acts or omissions which Defendant CandyLeBlanc can reasonably foresee, would be likely to cause injury to the Royal Bank ofCanada or to the Plaintiff Andre Murray, namely not applying reasonable effort ininforming Plaintiff Andre Murray of the upcoming Mortgage Sale which Plaintiff AndreMurray holds a $80,000 Mechanics Lien on the subject Property, so that Plaintiff AndreMurray could attend the Mortgage Auction and with all fairness have an opportunity tobid on the subject property.175. Defendant Candy LeBlanc claims to have sent a Notice of Mortgage Sale toPlaintiff Andre Murray at 29 Marshall Street, Fredericton by registered Canada Post mail,which Plaintiff Andre Murray was not notified of, and consequently the package wasreturned to Defendant Candy LeBlanc as unclaimed. Because of the Negligence ofDefendant Candy LeBlanc who did not send a second notice by registered mail or anynotice by regular mail, Plaintiff Andre Murray was not in attendance at the July 16,2009Mortgage Sale. As a consequence of not being at the Mortgage sale, Plaintiff AndreMurray has suffered damages, costs of litigation and loss of income and further damagesas a result.176. Defendant Candy LeBlanc, was Negligent and had a Duty of Care to the Court toensure that as assistant to Defendant George H. LeBlanc, all information from herpresented to the Court was accurate and trustworthy.177. Defendant Candy LeBlanc, was Negligent and had a Duty of Care to the Court toensure that as assistant to Defendant George H. LeBlanc, to knowingly further a Fraudupon the Court, by Defendant George H. LeBlanc is against what societal norms wouldconsider Moral Conduct.

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178. Defendant Candy LeBlanc, did have duty of care to inform the Plaintiff AndreMurray, after Plaintiff Andre Murray, on or about October 20th, 2009 enquired by phoneregarding the outcome of the October 20th, 2009 Ex Partee Hearing. Defendant CandyLeBlanc, did not inform Plaintiff Andre Murray of the imminent eviction which was totake place forthwith. Defendant Candy LeBlanc's negligence in informing PlaintiffAndre Murray of the imminent eviction, did contribute to unnecessary emotional painand suffering experienced by Plaintiff Andre Murray, which culminated at the surpriseeviction, caused Plaintiff Andre Murray to be temporarily homeless and continuedonward from then on.Defendant George H. LeBlanc179. Defendant George H. LeBlanc, did act as Solicitor of Record for the Royal Bank ofCanada, causing a mortgage sale to occur, allegedly pursuant to the Property Act of NewBrunswick.

180. Defendant George H. LeBlanc, was Negligent and had a Duty of Care to ensurethat as Solicitor of Record for the Royal Bank of Canada, he must take reasonable care toavoid acts or omissions which Defendant George H. LeBlanc can reasonably foresee,would be likely to cause injury to the Royal Bank of Canada or to the Plaintiff AndreMurray, namely not applying reasonable effort in informing Plaintiff Andre Murray ofthe upcoming Mortgage Sale which Plaintiff Andre Murray holds a $80,000 MechanicsLien on the subject Property, so that Plaintiff Andre Murray could attend the MortgageAuction and with all fairness have an opportunity to bid on the subject property.181. Defendant George H. LeBlanc, did acquire a Court Order, October 20th, 2009, fromthe Moncton Trial Divison, signed by Justice Zoe! R. Dionne, the Order was obtained bythe making of misrepresentations constituting a fraud upon the Court.182. Defendant George H. LeBlanc, did cause the illegal eviction of Defendant AndreMurray from his Residential Leasehold Tenancy of 31 Marshall Street, Fredericton.183. Defendant George H. LeBlanc, did cause the unlawful eviction of Defendant AndreMurray from his Residential Leasehold Tenancy of29 Marshall Street, Fredericton.184. Defendant George H. LeBlanc, did wrongfully interfere with Plaintiff AndreMurray's personal property located at 29 Marshall Street, further, did deny access to thesubject personal property, thereby did constitute conversion. The Defendant George H.LeBlanc converted the Plaintiff Andre Murray's personal property to his or her own useand excludes the owner Plaintiff Andre Murray from use and enjoyment of them.185. The Plaintiff Andre Murray claims that the actions of the Defendant George H.LeBlanc constitute an intentional or negligent infliction of mental harm.186. Defendant George H. LeBlanc, did commit intentional infliction of mentalsuffering or nervous shock by the flagrant or outrageous conduct of knowingly evicting

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Plaintiff Andre Murray from the 31 Marshall Street property, after providingmisrepresentations constituting a fraud upon the Court and furthermore purposefully notinforming Plaintiff Andre Murray of the pending eviction Order and as a result causedfurther injury to Plaintiff Andre Murray.

187. Defendant George H. LeBlanc did continue to deny the fraudulent actions andconduct in a sworn Affidavit to the Court of Queens Bench, Trial Division, Judicialdistrict of Moncton, Dated January 13th, 2010.188. Defendant George H. LeBlanc did admit to the previously denied fraudulent actionsand conduct ina sworn affidavit to the Court of Queens Bench, Trial Division, Judicialdistrict of Moncton, in a new affidavit Dated after the Court Transcripts of theOctober 20th , 2009 Hearing before the Court of Queens Bench, Trial Division, Judicialdistrict of Moncton, where delivered to the Cox and Palmer office of Defendant GeorgeH. LeBlanc189. In the alternative, the Plaintiff Andre Murray states that the causes of the mentalsuffering and abuse described herein and the surrounding circumstances are within theexclusive knowledge and control of the Defendant George H. LeBlanc and the saidharassment would not have occurred but for the negligence of the Defendant George H.LeBlanc. The Plaintiff pleads and relies upon the doctrine of res ipsa loquitur.190. The making of misrepresentations constituting a fraud upon the Court by whichDefendant George H. LeBlanc, did to acquire a Court Order, October 20t\ 2009, from theMoncton Trial Division, signed by Justice Zoel R. Dionne, was that Solicitor George H.LeBlanc claimed to have had served the Amended Notice of Motion upon the premises of29 Marshall street on the 13th day of October 2009, when in fact the Amended Notice ofMotion could not have been served on the property at that time because, the AmendedNotice of Motion was signed dated October 14,2009 and Date Stamped by MonctonTrial Division, Client Services as being submitted to the Court October 15, 2009 twodays after the alleged Service occurred.191. The further making of misrepresentations constituting a fraud upon the Court bywhich Defendant George H. LeBlanc, did to acquire a Court Order, October z o " , 2009,from the Moncton Trial Division, signed by Justice Zoel R. Dionne, was that SolicitorGeorge H. LeBlanc submitted two affidavits of Service, by Process Server DaveDaneliuk, which claimed to have served Documents upon the premises of29 Marshallstreet on the 13th day of October 2009, and fraudulently misrepresented 4 out of9 serviceattempts on the property, from October 5, 2009 to October 10,2009. Defendant GeorgeH. LeBlanc, was Negligent, knew better or aught to have know the truth, which wasDefendant George H. LeBlanc had only sent the document to the process servingcompany, Atlantic Document Services, October 6, 2009 and it was not possible for thefirst 4 claimed service attempts to have in fact occurred and service had not in fact starteduntil possibly October 7,2009, if at all. Defendant George H. LeBlanc had a duty of careto provide the Court with truthful, accurate information, was negligent in doing so.Because of the misrepresentations contained in documents submitted to the Court, the

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Court was mislead by Defendant George H. LeBlanc, in believing the exaggeratednumber of attempts of personal service, when in fact that subject documents could nothave been served on the property 4 out of the 9 times claimed, and mislead the Court inbelieving there where circumstances which required the Court to Order substitutedService.192. George H. LeBlanc, did to acquire a Court Order, October 20th, 2009, from theMoncton Trial Division, signed by Justice Zoel R. Dionne, by engaging in prohibitedconduct according to the Law Society of New Brunswick's Code of ProfessionalConduct CHAPTER EIGHT Page 31 -32 which states "Other prohibited conduct - 10.When acting as an advocate for the client the lawyer shall not (v) knowingly attempt todeceive or participate in the deception of the court or influence the course of justice byoffering false evidence, misstating facts or law, presenting or relying upon a false ordeceptive affidavit, suppressing what ought to be disclosed or otherwise assisting in anyfraud, crime or illegal conduct;"

193. Defendant George H. LeBlanc, did have duty of care according to LAW SOCIETYACT, s.N.B. 1996, chapter 89, section, Section 2 , 5 . "It is the object and duty of theSociety a) to uphold and protect the public interest in the administration of justice" whichis a legal obligation imposed on him, requiring that he adhere to a standard of reasonablecare while performing any acts that could foreseeably harm others.194. Defendant George H. LeBlanc, did have duty of care, to not send the FrederictonSheriffs Department, to enforce a Court Order which had been obtained by his Fraudupon the Court, to vacate the Plaintiff Andre Murray and any other occupants from 29Marshall Street, Fredericton New Brunswick, and because Defendant George H. LeBlancdid the very act, he was Negligent, he either knew or should have known his actionswould cause foreseeable harm, and further exacerbated the damages caused to thePlaintiff Andre Murray.195. Defendant George H. LeBlanc, did have duty of care to inform the Plaintiff AndreMurray, after Plaintiff Andre Murray, on October 20th, 2009 enquired bye-mailregarding the outcome of the October 20th, 2009 Ex Partee Hearing. Defendant GeorgeH.LeBlanc, did not inform Plaintiff Andre Murray of the imminent eviction which wasto take place forthwith. Defendant George H. LeBlanc's negligence in informing PlaintiffAndre Murray of the imminent eviction, did contribute to unnecessary emotional painand suffering experienced by Plaintiff Andre Murray, which culminated at the surpriseeviction, caused Plaintiff Andre Murray to be temporarily homeless and continuedonward with further attacks from then on.196. Defendant George H. LeBlanc did intentionally interfere with contractual relationsand economic interests of Plaintiff Andre Murray. Defendant George H. LeBlanc didintend to evict Plaintiff Andre Murray despite knowledge of the fact that Plaintiff AndreMurray was a self employed Artist, in all likely hood working from home, and that theeviction would cause an economic loss to the Plaintiff Andre Murray resulting from theinterference with Plaintiff Andre Murray's method of gaining his living. Because the

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thOctober 20 2009 Order to vacate was achieved by a fraud upon the Court then the actwas by illegal means. Plaintiff Andre Murray did experience a loss of income directlybecause of this.197. Sheriffs Act, R.S.N.B. 1973, c. S-8 12 states "The solicitor who issues a process and theparty onwhose behalf he is acting are severally liable to the sheriff for executing it." The DeputySheriffs acted onwhat was apparently a Lawful Order of the Court. That the Orderswhereimpugned and obtained by Fraud upon the Court, Defendant George H. LeBlanc, The RoyalBank of Canada and 501376 N.B. Ltd. a body corporate arejointly and severally liable to theSheriff for executing the unlawful Order to Vacate Plaintiff Andre Murray from 29 MarshallStreet and the damages thereby caused.198. Defendant George H. LeBlanc claims to have sent a Notice of Mortgage Sale toPlaintiff Andre Murray at 29 Marshall Street, Fredericton by registered Canada Post mail,which Plaintiff Andre Murray was not notified of, and consequently the package wasreturned to Defendant Candy LeBlanc as unclaimed. Because of the Negligence ofDefendant George H. LeBlanc who did not send a second notice by registered mail or anynotice by regular mail, Plaintiff Andre Murray was not in attendance at the July 16, 2009Mortgage Sale. As a consequence of not being at the Mortgage sale, Plaintiff AndreMurray has suffered damages, costs of litigation and loss of income and further damages199. Defendant George H. LeBlanc, did have duty of care to inform the Plaintiff AndreMurray, when Plaintiff Andre Murray, on or about October 20th, 2009 enquired by phoneto the Office of Cox and Palmer, regarding the outcome of the October 20th, 2009 ExPartee Hearing. Defendant George H. LeBlanc, failed to inform Plaintiff Andre Murrayof the imminent eviction which was to take place forthwith. Defendant George H.LeBlanc's negligence in informing Plaintiff Andre Murray of the imminent eviction, didcontribute to unnecessary emotional pain and suffering experienced by Plaintiff AndreMurray, which culminated at the surprise eviction, caused Plaintiff Andre Murray to betemporarily homeless and continued onward from then on.Defendant Royal Bank of Canada200. Defendant Royal Bank of Canada is a financial institution, providing bank Servicesand is officially headquartered at 1, Place Ville-Marie Montreal, Quebec, Canada, H3B2E7. Defendant Royal Bank of Canada in a vicarious manner, in this case, through a legalsubstitute is liable (vicarious liability) for the actions and damages caused by SolicitorGeorge H. LeBlanc, and other agents acting on RBC's behalf.201. Julie Ruggiero, a Collections Associate for Royal Bank of Canada who's office islocated in Montreal, Quebec, Canada. Defendant Julie Ruggiero did request thatDefendant Solicitor George LeBlanc an Order of the Court to vacate Plaintiff AndreMurray from peaceful possession and quiet enjoyment of his Leasehold Residence at 29Marshall Street, Fredericton and or any other occupants, in spite of being aware of theexistence of a Lease to the same property (as advised by Defendant Solicitor GeorgeLeBlanc) held by Tenant and Lease Holder Plaintiff Andre Murray.

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202. Note ..... .Intentional interference with contractual relations203. Julie Ruggiero, was Negligent and had a Duty of Care to ensure that as aCollections Associate for Royal Bank of Canada, she must take reasonable care to avoidacts or omissions which Defendant Julie Ruggiero can reasonably foresee, would belikely to cause injury to the Plaintiff Andre Murray, namely contributing to harm byrequesting the Ordering of the eviction of Plaintiff Andre Murray from a property whichPlaintiff Andre Murray .204. Andreen Tranchell, is a Property Management Coordinator with Centract RealProperty Recovery Services, believed to be retained by Julie Ruggiero CollectionsAssociate for Royal Bank of Canada. Andreen Tranchell Office with Centract is located39 Wynford Drive Toronto, ON M3C 3K5. Andreen Tranchell, is believed to haverequested ARA Fredericton Appraisal Associates Ltd., to cause the appraisal 29 MarshallStreet and 31 Marshall Street, Fredericton, in response to this request, employee JohnCarter, a appraiser employed by ARA Fredericton Appraisal Associates Ltd. wasassigned this task and did attend 29 Marshall Street and 31 Marshall Street, Fredericton,at approximately 7 pm, on or about November 9th 2009.205. Andreen Tranchell has in a vicarious manner; in this case, through a legal substituteis liable (vicarious liability) for the actions of John Carter and any other agents acting onher behalf.Defendant Steven J. Hill

206. Defendant Steven J. Hill did attend the July 16,2009 Auction ofthesubject Mortgage, as agent for Cox & Palmer, to secure the interests of DefendantRoyal Bank of Canada.

Defendant Atlantic Document Service Ltd.207. Defendant Atlantic Document Service Ltd. did send Defendant Dave Daneliuk tothe 29 Marshall Street property, Fredericton, New Brunswick to personally serve thesubject: a. Notice of Action with Statement of Claim attached (FORM 16 A) Dated atMoncton, New Brunswick, September 17th, 2009.

b. Notice of Motion (FORM 37 A) Dated at Moncton, New Brunswick,September 17th, 2009.

c. and supporting affidavit documents .and in this capacity Defendant Atlantic Document Service Ltd. has in a vicariousmanner, in this case, through a legal substitute is liable (vicarious liability) for theactions of Defendant Dave Daneliuk a.k.a. David A.Daneliuk and any otheragents acting on there behalf.Defendant Julie Ruggiero

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208. Defendant Julie Ruggiero, a Collections Associate for Royal Bank of Canadawho's office is located in Montreal, Quebec, Canada. Defendant Julie Ruggiero didrequest that Defendant Solicitor George LeBlanc an Order of the Court to vacate PlaintiffAndre Murray from peaceful possession and quiet enjoyment of his Leasehold Residence at29 Marshall Street, Fredericton and or any other occupants, in spite of being aware of theexistence of a Lease to the same property (as advised by Defendant Solicitor GeorgeLeBlanc) held by Tenant and Lease Holder Plaintiff Andre Murray.209. Defendant Julie Ruggiero, was Negligent and had a Duty of Care to ensure that asa Collections Associate for Royal Bank of Canada, she must take reasonable care toavoid acts or omissions which Defendant Julie Ruggiero can reasonably foresee, wouldbe likely to cause injury to the Plaintiff Andre Murray, namely contributing to harm byrequesting the Ordering of the eviction of Plaintiff Andre Murray from a property whichPlaintiff Andre Murray _Defendant Andreen Tranchell210. Defendant Andreen Tranchell, is a Property Management Coordinator withCentract Real Property Recovery Services, believed to be retained by Julie RuggieroCollections Associate for Royal Bank of Canada. Defendant Andreen Tranchell Officewith Centract is located 39 Wynford Drive Toronto, ON M3C 3K5. Defendant AndreenTranchell, is believed to have requested ARA Fredericton Appraisal Associates Ltd., tocause the appraisal 29 Marshall Street and 31 Marshall Street, Fredericton, in response tothis request, employee Defendant John Carter, a appraiser employed by ARA FrederictonAppraisal Associates Ltd. was assigned this task and did attend 29 Marshall Street and 31Marshall Street, Fredericton, at approximately 7 pm, on or about November 9th 2009.211. Defendant Andreen Tranchell has vicarious liability for the actions of DefendantJohn Carter and any other agents acting on her behalf.Defendant, City of Fredericton212. Defendant, City of Fredericton, N.B. Canada has a department called TheFredericton Police Force and did send 3 Fredericton Police Force members to the 29Marshall Street Fredericton, New Brunswick on October 23, 2009.213. Defendant, City of Fredericton has in a vicarious manner, in this case, through alegal substitute is liable (vicarious liability) for the actions and damages caused by thesubject members of The Fredericton Police Force in the illegal and unlawful eviction ofPlaintiff Andre Murray from his lawful and legal Residential Leasehold occupancy of 31Marshall Street, Fredericton on the 23rd day of October 2009.214. The City of Fredericton is also liable to the Plaintiff Andre Murray for damagesunder the Police Act, S.N.B. 1977, c. P-9.2, as amended. According to of the Police Act,section 17(1) "A municipality is 1able in respect of a tort committed by a member of the policeforce in the performance or purported performance of his or her responsibilities under section 12in the same manner as a master is liable in respect of a tort committed bythe master's servant in

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the course of the servant's employment where (a) a municipality is maintaining a police force, (b)a municipality is contracting under paragraph 4 (c) for the services of a municipal police force,and (c) a municipality has established a board under section 7." Accordingly The City ofFredericton is liable inrespect of a tort committe