我跟你们打个招呼我明天到多伦多市中心商业法庭

唐炜臻

高等法院，阻止 司法欺诈。我发现两个律师诈骗 $5000 以上的刑事犯罪，看法官管不管。
地址是：

330 University Ave， 大学街330 号。
时间早上 9:30
我每天法律事务很多，比一般律师很多，文件自己准备。

下面是我自己写的动议叫“NOTICE OF MOTION "





NOTICE OF RESPONDING MOTION

Take notice that the respondents will makea counter motion to the  representativecounsel to the class of Canadian Investors, herein, to be heard by a   JUDGE OF Superior court the commercial liston Nov. 12, 2015 at 9:30am, at the 330 University Avenue, Toronto

The proposed method of hearing:

The motion is to be heard Orally.   

The motion for 1.    Order to dismiss the motion brought by representative counsel, Kelley McKinnon 2.    Order to repatriate all the money previously, wrongly ordered and paid $201,352.42 to the representativecounsel of Gowling by Justice Newbould

3.    Punitive damage of substantial harm caused to the Canadian investorsclass and the respondents of 5 million dollars4.    Order to unfreeze all the funds frozen by this court to the owners of the funds     5.    Such further and other relief as the respondents request and thehonourable Court may permit.THE GROUND FOR THE COUNTER MOTIONARE:

1.      The funds frozen by this court for the purpose of investigation ofOSC and it has been frozen over six years.

2.      The funds frozen were my personal fund borrowed by my wife and Ifrom TD Canada Trust and funds of two new other investors, Mr. Si Yi Qiuand  Guosheng Wang afterFeb. 27, 2009

3.      The funds have been argued a number of times before the superiorcourt, 2009 beforeJustice Pepall, 2010 before Justice Pepall,  2011 before Justice Nordheimer.

4.      When I applied for the funds toretain counsel and Justice Nordheimer tried to order and grant my application,the counsel for OSC, for the crown, the representative counsel all opposedunder the name of my investors and deprived my constitutional rights to have acounsel  and full defence and answer.   

5.      Therepresentative counsel, Ms. Kelley McKinnon, only represent about 10 out of 260investors. She  must be  a very good female friend of many judges,was intentionally mislead this honourable court and Justice Newbould  that only issue  is reasonableness in order to steal money from me, my family and other two investors and defraud the investors and the public.When  Therepresentative counsel, Ms. Kelley McKinnon, apply to use my funds and funds of theother two investors, Mr. Yi Si Qiu and Guosheng Wang whom the representativecounsel did not serve, the counsel for Tom Tong, the applicant,  for OSC and for the Crown office alldisappeared  

6.      The representative counsel not appointed and authorized by theCanadian investors class, only 10 investors contacted them by emails, the fee should be paid bythe court or the investors whoever contacted the counsel and the counsel workfor them.

7.      The representative counsel was not appointed and not authorizedby the respondents.

8.      The representative counsel is not a party to the case,not an applicant, nor any of the respondents to this courtcase, but $201,352.42  a theft and robberyusing the court andlegal process.

9.      The representative counsel by did nothing for my investors, butcaused  harms to hundreds of investors,interfere judicial due process and deprived the respondents’ constitutional rights to have a counseland it is obstruct of justice.

10.  The representative counsel is stealing money from me and myinvestors and defraud investors, using our money to work for themselves.

11.  The order of the honourable court made on October 8, 2009 andappointed  the representative counsel wasin error and failed to observe the principles of fundamental justice and alsomade error in law and based its decision on erroneous or incompleteinformation.

12.  The order of the honourable court made on Dec 6, 2013 to pay therepresentative counsel from my personal money and money of two individualinvestors  was in error and failed toobserve the principles of fundamental justice and also made error in law and basedits decision on erroneous or incomplete information. The investors therepresentative counsel represented had no money.

13.  There was no proceeds of crime and nothing frozen was illegal money and nothing to distribute torepresentative counsel and investors.

14.  All my companies did nothing wrong and had all charges withdrawn onaugust 22, 2013 and all cease trade orders for the corporation lifted andfreeze order to be lifted.

15.  Most of the investors are not the owner of the account, are notentitled, no does the representative counsel, it is not whether itwas not and it is not reasonable or not to charge to account of my Oversea Chinese FundLimited Partnership, it is not right to charge theaccount.

16.  Charter of rights and freedoms s. 24 (1) Anyone whose rights or freedoms, as guaranteed by thisCharter, have been infringed or denied may apply to a court of competentjurisdiction to obtain such remedy as the court considers appropriate and justin the circumstances.   

THE FOLLOWINGDOCUMENTARY EVIDENCE WILL BE USED AT THE HEARING OF THE COUNTERMOTION: 1.   Theaffidavit of Weizhen Tang sworn November 09, 20152.   Suchfurther and other evidence as Weizhen Tang may advise and this honourable courtmay permit. Date: November 10, 2015

WEIZHENTANG

Silk Court

Richmond Hill

Ontario

L4B 4A4

Tel:416-886-8715

Email: [email protected]

For the RESPONDENTs

TO:

GOWLINGLAFLEUR HENDERSON  LLP

BARRISTER & SOLICITORS

SUITE 1600, 1 FIRST CANADIAN PLACE

100  King Street West

Toronto, Ontario M5X 1G5

KELLEY MCKINNON LSUC No. 33193C

ALEX ZAVAGLIA LUSC. No. 57622J

Tel: 416 369-7298

Fax: 416-862-7661

Representative Counsel for the CanadianInvestor Class

                             

ANDTO:

STOCKWOODSLLP
Barristers
TD North Tower, 77 King Street West
Suite 4130, P.O. Box 140
Toronto-Dominion Centre
Toronto, Ontario, Canada M5K 1H1
Direct:   (416)593-2487 |  Fax:  (416) 593-9345 , Mobile:  (416) 319-4440

For Ontario Securities Commission

ANDTO:

BENNETTJONES LLP

BARRISTERSAND SOLICITORS

1FIRST CANADIAN PLACE

SUITE 3400, TORONTO

ONTARIO          M5X 1A4

LINCOLINCAYLOR/MAUREEN WARD

TEL:416-863-1716

Lawyersfor the Receiver, Tom Tong

唐炜臻

唐炜臻在加拿大打老虎

Kelley McKinnon is a partner and head of the securities litigation practice at Gowlings' Toronto office.

Kelley held senior roles at the federal Competition Bureau and the Ontario Securities Commission, giving her unique insight and strategic perspective into regulatory risk and process, including in cross-border regulatory matters. At the Competition Bureau, she was the Senior Deputy Commissioner of Competition, heading the Mergers Branch and participating in other competition enforcement and policy matters across the Bureau as a member of the Senior Management Committee and periodically as the Acting Commissioner of Competition.  

Formerly the Deputy Director of Enforcement and Chief Litigation Counsel at the Ontario Securities Commission, Kelley litigated some of the most complex securities cases in recent years, including the OSC intervention on Danier Leather at the Supreme Court of Canada. At the OSC, Kelley provided strategic direction for enforcement prosecutions, civil litigation affecting the Commission (including class actions) and compliance and registration disputes. Kelley was a member of the Canadian Securities Administrators Enforcement Committee and has lectured extensively at the North American Securities Administrators Association. At the OSC from 2003 to 2008, Kelley brings an unprecedented depth of knowledge and insight into securities litigation, regulatory compliance and ways to effectively deal with multiple regulators in Canada and abroad.

At Gowlings, Kelley has conducted highly sensitive internal corporate investigations, and handled multiple securities class actions, corporate disputes (including representing shareholder funds in the Magna dual share structure hearings) and defence of numerous regulatory matters. Kelley has appeared before all levels of court in Ontario and before the Supreme Court of Canada, in addition to many regulatory tribunals. She appeared on the recent Supreme Court of Canada constitutional reference to determine whether the federal government has the authority to create a single securities regulator for Canada. Kelley acted for the intervener, the Ontario Teachers' Pension Plan Board.

In addition to her securities expertise, Kelley was a partner at another major law firm and vice chair of the litigation department, practising litigation for 13 years. She conducted complex commercial litigation, including contested banking litigation and civil fraud, international disputes under mutual legal assistance legislation, numerous regulatory hearings, and the defence of both criminal and quasi-criminal cases. She had a further specialty in privacy disputes, handling complex FOI requests and multiple proceedings before the Information and Privacy Commissioner. During her articling year, Kelley clerked to the Justices of the Court of Appeal for Ontario.

In May 2011, Kelley was appointed a member of the Ontario Securities Commission Enforcement Advisory Committee, which provides feedback and advice to the OSC on enforcement issues, including policy and procedure initiatives.

Kelley frequently comments on securities developments in the media. Her appearances include:

BNN's Headline in March 2012 to discuss Investor Class Action Lawsuits. Click here to watch part one. Click here to watch part two. Click here to watch part three.
CBC's Lang & O'Leary Exchange in December 2011 to discuss the SCC's decision on the proposed Canadian Securities Act. Click here to watch the segment.
BNN's Headline in December 2011 to discuss the SCC's decision on the proposed Canadian Securities Act. Click here to watch the segment.
BNN's Headline in September 2011 to discuss conflicts of interest for research analysts. Click here to watch the segment.
BNN's Headline in September 2011 to discuss Sino Forest. Click here to watch the segment.
BNN's Headline in August 2011 to discuss OSC issuing a cease trade on Sino Forest. Click here to watch the segment.
BNN's The Close in May 2011 to discuss the OSC and insider trading. Click here to watch the segment.
CTV's W5 in October 2010 to discuss affinity fraud after 800 people in Toronto's Caribbean community lost $25 million in an alleged investment scheme. Click here to watch the segment.
BNN's Headline in October 2010 to discuss the appointment of Howard Wetston as the new chairman of the Ontario Securities Commission. Click here to watch the interview.
BNN's The Close in July 2010 to discuss Canada's first criminal code conviction for insider trading. Click here to watch the interview.
Investment Executive in November 2009 to discuss the Inquiry into Financial Services in Australia, global regulation, and its potential impact on advisors in Canada. Click here to watch the interview.
BNN's SqueezePlay in October 2009 to discuss American fraud squads. Click here to watch the interview.
BNN in September 2009 to discuss an alleged Ponzi Scheme in Alberta. Click here to watch the interview.
BNN in August 2009 to discuss the SEC and changes to enforcement. Click here to watch the interview (begins at the 3:55 mark).
BNN's Headline in August 2009 to discuss the Drabinsky fraud sentences. Click here to watch part one of the interview, here for part two and here for part three.
BNN's Market Morning in March 2009 to discuss Ponzi schemes, securities regulations and investor protection. Click here to view the interview.
Kelley is a sought after teacher and lecturer. She taught Trial Practice Skills since 1994 at Osgoode Law School and Queen's, and was a team leader at the Intensive Trial Advocacy Workshop for lawyers for many years. Since 2004, she has taught North American investigators and securities lawyers in trial skills and strategy, including the use of expert evidence and electronic evidence. She also taught corporate governance at Queen's in 2009.

唐炜臻

zhangyd 发表于 2015-11-11 21:54
老唐英文好棒！

Monday, August 15th, 2011  before Justice Nordheimer  page 14   

There's a certain apparent conflict in the views of two agencies of the same government in that regard, but be that as it may, those things can happen, because they have   different interest to protect

There's a certain apparent conflict in the views of two agencies of the same government in that regard, but be that as it may, those things can happen, because they have               

The issue then presents itself, from my  perspective,  as I believe at one point    I referred to this as being akin to a  Rowbotham application.  Because either  on a strict Rowbotham application, I  would order the charges stayed until   such time as the Attorney General  provide counsel.   That would be at public expense.   The issue then becomes why the taxpayers in the Province of   Ontario should, in the first instance,  fund Mr. Tang's defence if Mr. Tang has  monies that could be used for that purpose, regardless of other claims by other people  to those matters.

This  matter proceeded, at least  initially, and it might still, on the  basis that there was no real dispute that that $200,000 of  funds belonging to Mr. Tang had gone into this particular account, even though it may be that subsequent to that other monies came in and others went out such that  you can't tell one dollar from the other.  But there was no dispute that  at least $200,000 of Mr. Tang 'sown money went into this account.  With that factual premise,

Monday , August 15th, 2011                            p  15

the issue then becomes does the Court have the right to order that those funds be used to pay for Mr. Tang's constitutional rightto counsel, as an -- in priority , for lack of a better word, to any claims that any people may have in civil proceedings , as essentially execution creditors or execution creditors in waiting or however you wish to put it, since some, I assume ,don 't  have yet judgments against Mr. Tang in terms of their claim .   

In other words , do their claim that these funds might be used to redress their losses in some fashion have to take a back seat to Mr . Tang 's right to use those funds to fulfill his constitutional rights to counsel and to make full answer and defence?

人生苦短

老唐英文好棒！