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 Written Reply to the Respondent Memorandum of Facts and Laws 

A, Violation of Federal Court Rules 221.

1,As a proposition to not hear any evidence during Motion to Strike, all facts are supposed to be taken as true. But the Order basically denies all facts of unlawful actions as true, even goes so far as to claim there is no material fact. Declaring this rule does not apply is a violation of Federal Court Rules 221.

B,Lack of expertise 

2, Does the Judge have the necessary technology expertise to make an assessment about ultrasound radiation?

C, The case can be saved by amendment 

3,T Respondent claims that this case is beyond salvation. But it can be done by reducing to such a simple case that happened in June 20,2021, well within two years limit with unlawful arrest, detention and impounded vehicle, a fabricated mental illness case with intent to detain me in order to do harm and murder. 

D, Facts supporting unlawful detention 

4,During my stay in the mental unit, one radio player of a medium mailbox size, placed outside the room but close to the door with wall power socket, facing my hospital bed, same device seen also seen before behind my back at the poker table at the casino in New Brunswick, these kind of devices can be easily put into a backpack following me wherever I go. 

5, One day I was asked by the nurse to sit at a specific spot against the nurse office wall outside, that was unusual, typically the nurses would come to the patients with their machines, I declined the request and went to a spot of my own choice, later I went around the office and notice a fully stuffed mountain backpack put right on the opposite side of the wall where I was told to sit. Similar scenarios happened before when I worked as a trucker, these types of backpacks were placed facing the position where I would stand handling paper works with the shipping staff, or simply carried by individuals chasing me on foot wherever I went,including in the bathrooms.

E, The motive is self protection, not frivolous, vexatious and scandalous 

6，This case of me being suppressed and killed is an ongoing scenario with attacks getting more and more intensified. If this case gets struck down, the attackers will escalate the assault with more aggressive attacks. The none-stop nature of the assault indicates the determination to have the victim killed one way or the other. Like a recent incident on October 19,2024, I reported to the commander of RCMP Shaunovon detachment,  

“Hello Sgt.James 

I am writing to you to report a crime .

My neighbor who have claimed caring about me to call the police, have just cut down the tree fence seperating my yard from their yard, damaging my property.

They used to trespassing into my yard by cutting a hole in the fence, I reported the illegal trespassing to the police before. My roof has been cut open leaking water, my secondary fence near my house has been torn down before, they drove ATVs around my house during the night to get into my yard damaging my property for possible illegal purposes. 

I blocked the hole they cut in the fence to stop their trespassing, now they cut the whole fence down so they can trespass my yard freely.

I called the police 15 minutes ago about this incident. I thought you may want to know about this as well. 

They falsely claim to care about me, their true intent is to do harm to me.”

7, The attackers cut my yard for easy access into my property, carrying surveillance on me with better view and easy aiming and timing at me with their ultrasound radiation shooting devices. ”

8,The discriminating treatment between the attackers and me is manifested in the fact that no investigation into the criminal activities towards me while acting out of ordinary by using law enforcement measures to force wellbeing checks on me with false calls from the attackers. 

9,The wellbeing check needs evidence to believe that life is in danger. But the police acted on the false claims of care multiple times is obvious a bogus excuse to look for opportunities to do harm and an neglect of duty to say the least, with possible collusion.

10,No probable cause, no reasonable grounds, no evidence by the callers, to initiate police actions, while ignoring evidence of any kind by the Appellant, refuse to act citing not owing duty of care. This double standard treatment forms discriminating policing. 

11,No probable cause police actions means arbitrary authoritarian actions , from which the Charter Rights are intended to shield citizens. 

12,The none-stop nature of the attacks with police involved proves that the Appellant is acting in good faith to protect himself from more vicious attacks, not being frivolous and vexatious and scandalous. 

F,No cause of action present in the original Claims VS none existence of cause of action, 

13,Should unlawful arrest, search, detention and seizure of property be considered no cause of action? Can defamation be a cause of action?

14,The Respondent keeps labeling the case as lacking cause of action, making no comments as to why the Charter Rights or defamation or discriminating treatment are not the Causes of Action in this case. 

15,the Claims have not been struck down by the lower Court on the ground of no cause of action, therefore, no cause of action is not a relevant matter in this Appeal of the Order. 

G,Irresponsible way of litigation 

16, Burying this litigation with the burden of unrelated case laws is an irresponsible way of litigation. The Respondent refuses to engage any facts in this case while citing multiple case laws with no similarities to this case.

17,The Respondent cited many case law authorities but made no link to this case as to how those cases bear any relevance and resemblance to this case. It is the Respondent's responsibility to make that connection, showing what is in common that makes the case law relevant in this particular case, not leaving the Appellant and the Court to figure out if there is any connection or sharing anything in common at all.

18,Only borrowing the conclusions from various case authorities but ignoring the huge factual base differences between those cases, this kind of citing authorities become selectively detached to the particular facts of this case and can be universal arguments to any cases in any scenario. It makes no sense to dispose of this case. The Appellant can do the same by borrowing opposite conclusions from case laws and the litigation ends up as a fight of case laws.

19, The Respondent claims that the Appellant did not present cause of action in the original Claims, but didn't prove that there is no cause of action in the Claims. An Amended Claims can be done to find the right cause of action as demonstrated in the proposed amended Claims.