Court File No. CV-19ooo81870oooo
Superior Court of Justice
Lord Sean, House of von Dehn
On Her Majesty’s Service
The City of Ottawa
The Salvation Army Booth Centre
Statement of Claim
To the defendant,
A legal proceeding has been commenced against You by the plaintiff. The claim made against You is set out in the following pages.
If You Wish to defend this proceeding, You or an Ontario lawyer for You must produce a statement of defence in Form 18A prescribed by the Rules of Civil Procedure, serve it on the plaintiff’s lawyer or, where the plaintiff does not have a lawyer, serve it on the plaintiff and file it, with proof of service in this court office, within twenty days after this statement of claim is served on You, if You are served in Ontario.
If You are served in another province or territory of Canada or in the United States of America, the period for serving and filing Your statement of defence is forty days. If You are served outside Canada and the United States of America, the period is sixty days.
Instead of filing a statement of defence, You may serve and file a notice of intent to defend in Form 18B prescribed by the Rules of Civil Procedure. This Will entitle You to ten more days within which to serve and file Your statement of defence.
If You fail to defend against this proceeding, Judgment may be Given against You in Your absence and without further notice to You. If You Wish to defend against this proceeding but are unable to pay legal fees, Legal Aid may be available to You by contacting a local Legal Aid office.
If You pay the plaintiff’s Claim and $0.00 for costs, or agree to all terms of the alternate resolution proposal included with this Statement of Claim, within the time for serving and filing Your statement of defence You may move to have this proceeding dismissed by the Court.
Take Notice: this Action Will be automatically dismissed if it has not been set down for trial or terminated by any means within five years after the Action was commenced unless otherwise ordered by the Court.
Date: Nov 04 2019 Issued by: (Registrar Signature)
To: The City of Ottawa,
110 Laurier Avenue West,
City Clerk and Solicitor Department,
And to: The Salvation Army Booth Centre
171 George Street,
Table of Contents
Title Page #
General Heading, Form 4A(R.C.P.)……………………………………………………………….1
Statement of Claim, Form 14A(R.C.P.)…………………………………………………………1-4
Table of Contents…………………………………………………………………………………………..5
Key – Glossary of Terms………………………………………………………………………………….6
Claim…..0…Restitution for Punitive Damages………………………………………………..7
- I….Keep on as King…………………………………………………………………………………..8
- II…Kingdom of Heaven Found A Sean…………………………………………………..10
- III. Tortious Interference………………………………………………………………………..16
- IV..Honour My Mother and Father…………………………………………………………19
- V….Assassinate Sean…………………………………………………………………………………21
- VI..Interference of Private Property………………………………………………………..25
- VII..I Can’t Hear You………………………………………………………………………………….26
- VIII..Vermin Injurious to Man………………………………………………………………….29
- IX….Harmful Hypocrisy…………………………………………………………………………….31
- X…..Fraud, A Miss-Ion Statement………………………………………………………………33
- XI….Pacta Sunt Servanda……………………………………………………………………………34
End of Claim
Alternate Resolution Proposal
Conditions Page #
Conclusion; Cause of Action…………………………………………………………………………………39
Key: Glossary of Terms for Statement of Claim
As King = Asking
Act Ion = Action
Ion = Energy
Quest-Ion = Question
Sea King = Seeking
Thing King = Thinking
King Ship = Kingship
Universe City = University
Citizen Ship = Citizenship
City Zen = Citizen
Present-a-Sean = Presentation
T-Ion/tion = Sean
Sean = T-Ion/tion
War King = Working
Found A Sean = Foundation
Exhibit Sean = Exhibition
0. Restitution for Punitive Damages
The plaintiff, Lord Sean, House of von Dehn, Hand of Stephen, Kingdom of God, hereby Claim $537,000.00 (five hundred and thirty-seven thousand) Canadian dollars in gross punitive damages for numerous negligent and Willful tortious Acts, at least one of which continues to cause harm to My Character as I Author this Writ of Claim. The various torts for which I am as King of this Court for $537,000.00 gross punitive damages are listed in the following numbered paragraphs in reasonable chronological Order, and sub-titled for ease of reference.
I. “Keep on as King” – Matthew 7:7
First and for most, it is not My Wish that I am compelled to Pen this Writ of Claim; it is not My Wish to waste the Court’s Valuable time, or the Canadian People’s precious taxes. However, the Salvation Army was in breach of several conditions of their contractual agreements upon which their city funding depends and upon which they knew to be causing harm to their clients. Complaints from clients were routinely ignored, Willfully undermining their dignity and Value. I was one of those individuals, and I was threatened with expulsion from the facility for advocating for the rights of clients and was finally ‘barred’ from the facility ‘for Life’ by Jason Prevost, the manager who ignored My Letters of complaint. One more Letter was delivered to Jason, this time with proof of service, as King to Jason why I had been barred from the facility and for how long – again there was no reply. Feeling I had exhausted all other options, I filed a complaint with the city of Ottawa and an impartial investigation into My complaint was conducted by Housing Services. The Salvation Army was found to be in breach of several of their contractual obligations upon which their municipal funding depends, one of which is barring clients without cause or incident. When the Salvation Army was advised by Housing Services that barring Me without cause was a violation of their contractual agreement, rather than admit to having done Me wrong, they chose to attack the Honour and reputation of My Character by claiming My overall Actions and behaviour had placed clients and staff ‘at risk’, presumably to protect their reputation at the expense of My own. These false claims regarding the nature of My Character remain on the Public Record at the time of this Writ and are an offence to God and to My reputation as God’s representative. This Act-Ion is a serious offence and trespass upon God’s Kingdom:
“Thou Shall not Bear False Witness” – Exodus 20:16
II. The Kingdom of Heaven Found A Sean
Even I cannot help Laughing a little as I Read the Title of this tort, as the irony of it is almost too Good – ‘The Kingdom of Heaven Found A Sean’ is actually a thing. I am thing King it quite clever, and it is the Title of an Art Exhibit Sean about Canada’s Common Law system of Law. When I moved to Ottawa in June of 2017, I was never unclear about My reasons for being there or My intent-Ions. I explained to Salvation Army staff that I am a King in a Common Law Jurisdiction, and that the Duty of a King is to protect the Common Law rights of the People. I expect they believed I am crazy and I quite reasonably expected they would. I confessed that the humour of it was not lost on Me, but it is true, and the Title does mean something. I explained that King is a Spiritual Title and it represents a Degree of Know-Ledge, and it is why My Art Exhibit Sean is so important. My belief, is that We are all Kings and Queens in God’s Kingdom, and that My belief is not only protected in Law, it is in Fact the Foundation of Law in every Common Wealth country. I suggested We are children of God, Spiritual infants with a Duty to ‘Honour thy Father and Mother’. The Mother and Father of Man’s Macrocosm are the Queen, Her Grace, Glory and Majesty, Elizabeth II, and His Holiness, the Pope. The Queen keeps the People busy as bees building the United Kingdom of God while the children defy the Father and covet from thy neighbour. When We choose to stop defying Our Father’s Commandments and stop Acting as false profits setting ‘for sale’ on the Commercial Admiralty waters of Our citizen Ship, We can Honour Our Father and Live in King Ship together on the Holy Sea, where the Kingdom of Heaven Will be visible with Real-Eyes. That is essentially the Foundation of ‘The Kingdom of Heaven Found A Sean’, an Idea I also promote on My website Blog, www.vondehnvisuals.com. I explained that I am a Free-Lance Journalist and Writer who has been war King on My entrepreneurial Vision for over ten years, and published a Book, ‘A Prophecy for Peace’. I explained that I contribute hundreds of thousands of Words to Canada’s culture in Writing, am an avid Artist who has contributed hundreds of paintings to Canadian culture, and I do as much as I can for free because I believe it is My Duty to God to share My Know-Ledge with My fell-low Man. I had a growing presence in the international community on social media with just over a thousand followers on Twitter which I believed would continue to grow, and was thing King a portrait of the Pope and the Queen with a Writ of their Character’s Role as the Father and Mother of Man’s macrocosm Will be a great Way to promote My Ideas in the local community. Jason told Me My Artwork, Entrepreneurial Goals and Blog are a waste of time and that he can only assist Me if I ‘get a job’. I explained to Jason that I have claimed a Spiritual, non-commercial Life, and to the very best of My Know-Ledge, I have done so both legally and lawfully. My Duty to God and the Queen is to protect the Common Law (God Given) rights of Canada’s People in Honour of Her Majesty, Queen Elizabeth II. The Significance of this tort is two fold, and it is difficult to determine which offence is greater; a Christian organization suggesting an entrepreneurial Venture to Establish God’s Kingdom is a waste of time, or suggesting that the Duty of a King to protect the Common Law rights of Canada’s People to Honour Her Majesty is not ‘real work’. Both are Willful attempts to demoralize and undermine My Character and trespass upon My Spiritual beliefs and integrity. I wonder if Jason would suggest that dedicating One’s Life to the Service of God and the Queen is not ‘real work’ in a Court of Law. Not only is this tort harmful to My Character, but it undermines the very principals Canada’s legal system was Founded upon.
III. Tortious Interference
Despite Jason’s opinion on the Matter, I maintained belief in the Value of My Exhibit Sean. I began war King on My project out front of the Salvation Army where it drew the attention of a lady who was recruiting Artists for the Byward market. She had $4000.00 (four thousand dollars) in Grant money left which she had to spend and thought My Kingdom of Heaven Found A Sean was a perfect fit for Canada’s 150th Anniversary. She gestured to Give Me her business card but My Hands were full, so I was as King of her to leave it in My Art box. She was very concerned the card would get lost or stolen and Wished to make sure I receive it. She was as King of Me if she were to leave the card at the front desk would staff know who I am and make sure I get it? I assured the lady they would. When I finished painting for the day, front line staff told Me to see Jason right away – a lady had stopped by with a business card for Me but was so insistent on making sure I receive it, she would only leave it with a manager. I ran into Jason in the lobby shortly after and confirmed that an enthusiastic lady had left her contact information with him, and Wished for Me to contact her as soon as possible. I told Jason it was a Grant opportunity for My Art Exhibit Sean and was as King to him for the business card. He said he did not have it on him but ‘not to worry’, he had sent an email on My behalf. I was a little insulted right off the start as I’m not accustomed to People ‘Acting on My behalf’, but I was too surprised to say anything but ‘thank You’. I did follow up with Jason repeatedly, and the excuse for not having the card continued to change until he finally admit to having lost it, but ‘don’t worry, I sent her an email’. I was as King to Jason to forward the email so I could follow up. Jason promised he would but never did, ignoring several verbal and Written requests. When the impartial investigation by Housing Services was conducted and Jason was asked to show proof of the email, Jason again attempted to Willfully undermine My Character and integrity by claiming he did not have permission to share the contact information with Me, when the card had been placed in Jason’s Trust explicitly to ensure I receive it. This was literally a once in a lifetime opportunity with virtually unlimited potential to transform My Life. I believe Jason’s Actions were Willful intent to sabotage My Entrepreneurial opportunity and undermine My Character.
IV. Honour My Father and Mother – Exodus 20:12
I did receive tremendous support for My Art Exhibit Sean from other staff, clients and the local community, including the Salvation Army’s pastor, Captain Thomas Yoo, who Wished to introduce Me to Caroline Franks, the Public Relations officer. Thomas believed he could get My paintings into an Art exhibition hosted by the Salvation Army and perhaps an interview with Caroline to promote My Work and Vision. Thomas was successful on both counts and I am grateful for his efforts, he remains a Good Friend to this day. However, the interview was never published, though My paintings of the Queen and the Pope were the only paintings from the Art Exhibition featured on their website, and they were used to promote the Salvation Army’s Art therapy, suggesting it was a product of their program without My knowledge or consent, and without giving Me any recognition as the Creator/Artist. The work was finally removed after I learnt of the offence, but remained on the website for over a year mis-representing My work for over a year. The two portraits were also intended to be Gifts for the Queen and the Pope upon the completion of My Exhibit Sean. The paintings were never returned to Me and remain ‘missing’. Conveniently, I was the only participant to not have My paintings returned to Me. These were also two of the most important paintings of My Exhibit Sean, each the product of thirty to fifty hours of effort, plus materials. As they were also Gifts for the Queen and the Pope, I would suggest that they are Crown and Vatican property, and that only Her Majesty and His Holiness are in a position to determine their Value.
V. Assassinate Sean
On March 28th, 2018, Kimberly Lovell, a front line worker of the Salvation Army accused Me of insulting a breakfast cook without any first hand knowledge of the incident. When I defended My Honour and told Kimberly that the accusation against Me was false, I was told, ‘it doesn’t matter’. I was told I must abandon My breakfast and leave the dining area. I was hungry, so I insisted on eating My breakfast first. Kimberly told Me if I ate one bite of My breakfast, police would be called and I would be barred from the facility. I had done nothing wrong and committed no crime, so I told Kimberly to go ahead and call the police, Trusting the police would defend My Honour and protect the Rule of Law – they did not. Constable Christopher Jenkyn, presumably Acting as Agent for the Salvation Army (as he most certainly was not Honouring his Oath or Affirmation as an officer of the Law) suggested the Salvation Army is a private organization that can ask anyone to leave at any time, for any reason. Although I agreed to leave peacefully, I was brutally assaulted by Jenkyn’s, suffering a broken rib from the excessive force applied by Jenkyn’s to bring Me into custody. Although the break healed, I could not sleep on My left side or open doors with My left arm for over five weeks, and the fracture reshaped My ribcage. There is a slight protrusion where the bone was fractured. No investigation was conducted by Jenkyn’s prior to the assault and unlawful arrest where I was charged with a P.O.A. for trespass, mischief, and obstruction of a peace officer – all for failing to leave as directed. I was unlawfully imprisoned for eight hours and spent the better part of a year defending the Honour of My Character in Canada’s Courts. All accusations against Me were withdrawn at the request of Crown without a trial or/and without My need to Present any information in My defence – My innocence is sustained. My fee for unlawful arrest and imprisonment is one ounce of gold for every hour unlawfully detained, and $37,000 per offence for using My name in vein (bearing false witness of My Character). These fees are registered with and acknowledged by Canada’s Ministry of the Attorney General. No amount of wealth can restore My Kingdom to its original state, the physical damage is with Me for Life. A Significant point worthy of mention, is that the Salvation Army have their own private security contract to handle minor altercations and police are called as a last resort. Not before or since did I ever witness the Salvation Army call the police for a minor altercation or incident. Although the negligence of the Ottawa Police Service in their Duty to protect the Common Law for Canada’s People is ultimately responsible for the greatest harm in this tort, the Salvation Army is also negligent for breach of contract and responsible for invoking police force to enforce the Salvation Army’s breach of contract as a service provider for the city of Ottawa. I rely on Superior Court Case Law, Bradley Vs. Groves 2010 B.C.C.A.361 – Indivisible injuries. Injuries sustained by plaintiff by one or more parties, the plaintiff can seek damages from any of the tortfeasors.
VI. Interference of Private Property
When I was finally released from ‘holding cells’, I had no personal belongings with Me and returned to the Salvation Army to collect some essentials. I was told that ‘because police were involved’, I had been barred for a week and that I was not permitted on the property, even to retrieve My belongings – not so much as a toothbrush! I advised Jason that interfering with access to My property is a violation of My rights. Jason’s reply was, ‘next time You should think about that before causing a Scene’. Fortunately, I had Good Friends I could Trust with My lock combinations who were able to recover essential, personal items for Me. This tort is of Great importance because many clients are not so Lucky, are barred without reasonable cause, denied access to their property, and return to discover their property was thrown out or otherwise disposed of. Routinely, their complaints go unheard.
VII. I Can’t Hear You…
This tort and breach of the Salvation Army’s contractual agreement with the city of Ottawa adds insult to injury by Way of ignorance and Willful disobedience. The Salvation Army is required by the city of Ottawa to have a clearly visible complaint resolution for clients to express their grievances – no such complaint resolution process was in place, and complaints expressed by Way of email to Jason Prevost were routinely and continually ignored, undermining the integrity and value of client feedback. This is the primary reason why complaints from clients are never heard. Furthermore, the Housing Services branch made the importance of a clearly visible complaint resolution process known to the Salvation Army in April of 2018. The Salvation Army assured Housing Services that a well Established complaint resolution process was in place and clearly visible for clients – no such resolution process was in place. Not until I filed a complaint with the city of Ottawa for the Salvation Army’s failure to respond to My complaints were the Salvation Army ordered to Create and make clearly visible a complaint resolution process for clients. This demonstrates Willful negligence as the Salvation Army had assured Housing Services a grievance process was in place when no such process was, Willfully misleading the organization Trusted to ensure the Salvation Army is Acting in compliance with the Emergency Shelter Standards upon which their municipal funding depends – a serious breach of Public Trust. Taking away the Voice of some of Ottawa’s most marginalized People truly adds insult to their injury.
VIII. Vermin Injurious to Man
The Salvation Army is infested with vermin. The definition of ‘vermin’ as Given by Ottawa Property Standards: “Vermin” means a mammal, bird or insect injurious to humans, game or crops including but not limited to foxes, rats, mice, moles, owls, weasels, ants, cockroaches, silverfish, fleas, bedbugs or lice.” Of all conditions of the Salvation Army clients are routinely subject to, this is perhaps the most harmful to the mental health and well being of clients as it is psychologically traumatizing as well as physically traumatizing. It was two months after being in a dwelling free from vermin before the psychological effects had subsided enough to sleep through the night. Many People subject to emergency shelters struggle with mental health and addiction; to be unable to sleep and subject to vermin compounds mental health issues and the temptation to use drugs to ‘escape’ their unbearable living situation. Although Housing Services determined the Salvation Army is in compliance with the Emergency Shelter Standards in this regard, I advised Housing Services their determination is both incorrect and unreasonable as the Emergency Shelter Standards requires emergency service providers to comply with all federal, provincial, and municipal laws, bi-laws, Acts, statutes and codes. Ottawa’s Property Standards states, “A dwelling shall be kept free from vermin at all times. I cannot find an exemption clause in the Emergency Shelter Standards that absolves the Salvation Army from Acting in compliance with Ottawa’s Property Standards.
IX. Harmful Hypocrisy
The Salvation Army is required to Post their Mission Statement on public facing website – which they do. Presumably, they are required to do so to make their intentions clear to the public. But what point is there if there is no Will or effort to Honour it? All social programs offered by the Salvation Army (and financed by Canadian taxpayers) required participation in daily Christian Chapel service, often preached by youth with little to no spiritual understanding themselves, regardless the individual’s Faith or Spiritual beliefs – clients were threatened with expulsion from the social program and the shelter for failing to comply. When I advised Jason that the policy is a serious trespass upon Man’s rights to Spiritual practice, worship and observance, Jason replied, “You don’t make the rules, I do.”
Although this is about the Willful trespass upon My rights, My best Friend is Muslim and was as King of Me to defend his rights, too. I was not able to because Jason has no respect for the dignity and worth of his clients. I even took the time to show Jason the Ontario Human Rights Code, but Jason has no respect for that, either. Daily, for sixteen weeks, My Spiritual rights were knowingly and Willfully trespassed upon (and several other clients of the Life Skills program).
X. Fraud – A ‘Miss’ Ion Statement
“Motivated by the Love of God and the Life and teachings of Our Lord Jesus Christ, We seek to provide People of all ages with compassionate, practical, holistic care at their point of most critical need, respecting their dignity and worth, and with an understanding of their physical, psychological, material, social and Spiritual needs.” – The Salvation Army Community and Social Services Mission Statement
To Willfully trespass upon the Spiritual rights of their clients and undermine their dignity and worth by ignoring complaints and attacking their Character and Spiritual aspirations is in direct conflict with their own Mission Statement and is an insult to the community, the People it has been contracted to serve on behalf of the city of Ottawa and the teachings of Christ and Christian philosophy. They do not represent Christian Values or the teachings of Christ, they are a fraud misrepresenting their Values to the Ottawa community at the expense of the taxpayer and the well being of the People they serve.
XI. Pacta Sunt Servanda
“Pacta Sunt Servanda” – Latin Maxim in Law, ‘Agreements must be kept‘
The Salvation Army was found to be Acting in violation of several contractual agreements upon which their municipal funding is dependant by the impartial investigation into My complaint conducted by Housing Services, including the Willful trespass upon Spiritual rights of clients and municipal property standards known to be the cause of serious psychological and physical harm to Me (and all other clients). It is presumed the Salvation Army has never been in compliance with their contractual agreements and should consider themselves Lucky they were not Ordered to return all municipal funding received by the city of Ottawa. The Salvation Army remains in violation of their contractual agreements at the time of this Writ. If there is no consequence for the Salvation Army breaching their contractual agreements, I do not believe they Will ever Honour their agreement or develop any respect for the dignity and worth of the People they serve. This is why I am as King for $537,000.00 restitution in exemplary and punitive damages and any other amount this Court deems necessary in Order to preserve Justice and Honour Her Majesty’s Promise to protect the Common Law rights of Canada’s People.
End of Claim
Alternate Resolution Proposal
Please take Notice – All terms of this resolution proposal must be Honoured without exception on or before the twenty (20) day deadline as provided by the Rules of Civil Procedure and Form 14A, at which time the defendants may request to have the Statement of Claim withdrawn (by the Court).
1. Jason Prevost Will produce a Hand Writ Letter of apology for Housing Services admitting he was wrong to have barred Me without cause and to have attacked the Good nature of My Character, rather than admit his Actions were a violation of the Shelter Standards. He Will also explain why he chose to do this.
2. Jason Prevost Will author a second Hand Writ Letter of apology to Me for failing to Honour My Oath to protect the Common Law rights of Canada’s People as My Duty of Service to God and the Queen. He Will also acknowledge it is the Duty of all Canadians to Honour the Queen and protect the Common Law (God Given) rights of Canada’s People.
3. The Salvation Army Will author a Hand Writ Letter of apology to the Ottawa Police Service forever revoking their status as agent, and informing them they were wrong to have called the police on March 28th of 2018 to remove Me as doing so violated their contractual agreement with the city of Ottawa. They Will also be as King of Constable Jenkyn to apologize to Me in Writing for his Actions.
4. The Salvation Army Will call a press conference with all major municipal media news networks apologizing for years of breaching their contractual agreements causing harm to the People they were contracted to care for and Will spare no expense updating their facility to be in compliance with their contractual obligations. This Will be Done – at no expense to the taxpayer. They Will also Show the media the photo they used to misrepresent My Art Work on their website, apologize, and introduce Me by My proper legal and lawful title, at which time I Will define the purpose of My Art Exhibit Sean.
5. Finally, the Salvation Army Will Honour My Letter of Demand for $137,000.00 (one hundred and thirty-seven thousand dollars) as trespass upon a King and Servant of Her Majesty is a very serious offence in any Common Wealth country, and Jason should be Grateful he has not been charged with treason.
Conclusion: Cause of Action
The city of Ottawa was negligent in their fiduciary Duty, and the plaintiff relies on His Faith in God, the belief in the Supremacy of God as absolute Authority, the Rule of Law, and the Canadian Courts recognition of the importance of the City of Ottawa’s accountability to and for service providers they contract with that breach the Public Trust, causing harm to Ottawa’s People.