Let's Adore Jesus-Eucharist! | Home >> Directory of sheep and wolves
Mr. Douglas Elliott
Bill Whatcott's famous Gay Zombies Cannabis Consumers Association
Stefan handing out famous "Elliott-Approved" flyer
(titled "Love Sodomites, Hate Sodomy!")
in front of the CBC building on St. John Street, Quebec City.
1) S. Jetchick (2016-August-13)
2) D. Elliott (2016-August-14-1)
3) D. Elliott (2016-August-14-2)
4) S. Jetchick (2016-August-14)
5) D. Elliott (2016-August-15)
6) S. Jetchick (2016-August-16; "Defence E-mail")
7) D. Elliott (2016-August-16)
8) S. Jetchick (2016-August-17)
9) S. Jetchick (2016-September-11; Statement of Defence)
10) S. Jetchick (2016-September-19)
11) D. Elliott (2016-September-20)
12) S. Jetchick (2016-September-20)
13) S. Jetchick (2016-September-30)
14) J. Findlay (2016-November-02)
15) Belinda Wu (2016-November-04)
16) Nanda Singh (2016-November-07)
17) S. Jetchick (2016-November-08)
18) S. Jetchick (2016-November-16)
19) C. Elphinstone (2016-November-18)
20) D. Elliott (2017-January-19)
21) S. Jetchick (2017-Jan-23)
From the website of Cambridge LLP:
Cambridge LLP has filed a class action lawsuit on behalf of class representatives Christopher Hudspeth and George Smitherman. The lawsuit is against William Whatcott and others who dishonestly portrayed themselves as the «Gay Zombies» in order to distribute offensive literature at the Toronto Pride Parade on July 3, 2016.
For more information about this class action, email us at email@example.com or call 416-477-7077 and ask for a member of our Whatcott class action team.
You can also read the Statement of Claim, or view their press conference on YouTube (sorry, I don't have a better link yet).
This is the e-mail I sent them:
-------- Forwarded Message -------- Subject: Whatcott Class Action (Stefan Jetchick was one of the "zombies"!) Date: Sat, 13 Aug 2016 20:02:14 -0400 From: Stefan Jetchick To: firstname.lastname@example.org Good evening Sirs, I just found out a few minutes ago (through an e-mail from Bill Whatcott) that you are trying to file a Class action lawsuit: www.cambridgellp.com/whatcott-class-action I am deeply offended that my name is not mentioned on your website, as if all the credit for this courageous action belonged to Mr. Whatcott. (Well, OK, I admit he did most of the hard work, but still, I was there, and I handed out some of my flyers.) You can see small YouTube videos of me (and Bill's other courageous activists), as well as read my flyer, by visiting this web page: The Gay Zombies Cannabis Consumers Association Please stop insulting me by mentioning only Bill on your website. And please stop insinuating that Bill's friends are afraid of you. I'm not hiding. I'm not ashamed of what I did. Apart from that, have a really swell day, and God bless you! Stefan Jetchick [Usual full contact information]
P.S. The e-mail bounced right back! "Unknown address"! So I went to the "Contact" form of their website and copied it there and sent it again. I hope they will get it!
-------- Forwarded Message -------- Subject: RE: Whatcott Class Action (Stefan Jetchick was one of the "zombies"!) Date: Sun, 14 Aug 2016 11:54:51 +0000 From: Doug Elliott delliott (at sign) cambridgellp.com To: Stefan Jetchick CC: [Office Assistant to Mr. Elliott] Dear Mr. Jetchick: I would have been happy to mention you in our Statement of Claim and on our website had your name been disclosed to Pride Toronto. If you did disclose your name to Pride Toronto, please provide me any documentation that substantiated that. We used pseudonyms in our Statement of Claim and described Mr. Whatcott's companions based on how they were dressed in photos on Mr. Whatcott's website. Would please be kind enough to identify which of the marchers was you: - A member of the 'Gay Zombies who marched at the Toronto Pride Parade 2016 wearing a green body suit with a rainbow coloured 'tutu,' rainbow coloured flag around his neck and grey and black running shoes. - A member of the Gay Zombies who marched at the Toronto Pride Parade 2016 wearing a green body suit, a rainbow coloured mask, bow tie and briefs and white running shoes. - A member of the Gay Zombies who marched at the Toronto Pride Parade 2016 wearing a green body suit and a rainbow coloured hat, bow tie and boxers, with black sunglasses. - A member of the Gay Zombies who marched at the Toronto Pride Parade 2016 wearing a green bodysuit; a rainbow coloured 'tutu', black goggles and Black running shoes. - A member of the Gay Zombies who marched at the Toronto Pride Parade 2016 wearing a rainbow coloured hat, glasses, a green tee- shirt, blue jeans, and black shoes. Please identify which of the foregoing persons is you. Any assistance you can provide with identifying your fellow "courageous" marchers would be appreciated. We will amend our pleading as soon as you provide this information and update our website accordingly. Yours truly, Douglas Elliott [cid:image001.jpg@01CA92B3.C7B48BE0] toronto + burlington + ottawa R. Douglas Elliott LSM | Direct: 647-430-5378 Partner Certified Specialist in Civil Litigation email@example.com | www.cambridgellp.com TORONTO OFFICE: 333 Adelaide Street West| Fourth Floor| Toronto, Ontario, CANADA M5V 1R5 Phone: 416-477-7007 ext. 311 | Toll Free Phone: 1-877-684-1434 | Fax: 289-293-0318 CONFIDENTIALITY NOTE: This message and any attachments are intended only for the addressee(s) and may contain privileged or confidential information. Any unauthorized use or disclosure is strictly prohibited. If you received this message in error, please notify us immediately and we will correct our records. Please then permanently delete the original message and any attachments and destroy all copies. Thank you. [cid:image002.jpg@01CA92B3.C7B48BE0] Before printing, please think about the Environment! [My whole original message was copied here. From here on I just omit such repetitions, and don't mention it.]
-------- Forwarded Message -------- Subject: Hudspeth v Whatcott Date: Sun, 14 Aug 2016 12:21:35 +0000 From: Doug Elliott To: Stefan Jetchick CC: [Office Assistant to Mr. Elliott] Dear Mr. Jetchik: Further to my earlier message, I have now had a chance to review the link you sent to your own website. I see now that you were the "zombie" wearing the black goggles. We will amend our claim according. We look forward to your cooperation in identifying your companions. Douglas Elliott [Boilerplate as per his first reply From here on I just omit such repetitions, and don't mention it.]
-------- Forwarded Message -------- Subject: Re: Hudspeth v Whatcott Date: Sun, 14 Aug 2016 10:44:57 -0400 From: Stefan Jetchick To: Doug Elliott Good day Mr. Doug Elliott, >> I have now had a chance to review the link >> you sent to your own website. Great! I love it when people take the time to read before they ask silly questions! ;-) >> I see now that you were the "zombie" wearing >> the black goggles. It's not an important detail, but the goggles were actually totally clear! I had **removed** the lenses because it was such a hot day, but somehow the shadow made them look black. I purchased them here: www.leevalley.com/en/wood/page.aspx?p=70788 They are now, sadly, in some garbage bin in a washroom in Union Station in Toronto, along with my nice tutu... I should have kept them for a souvenir! >> We look forward to your cooperation in >> identifying your companions. Actually, apart from Bill, it was the first time in my life that I saw all the other ones. One of them was called Doug, or Dave, well, something starting with "D". But they were a hoot to work with! By the way, your e-mail server rejects my e-mails when I send them with my usual e-mail address (sjj@). It will make cooperation very difficult for me. Cheers, SJJ
Several e-mails were sent to-and-fro on Monday August 15, to solve problem of me being unable to reply with my usual e-mail address. It turns out Mr. Elliott was not blocking me, but the e-mail software on their server was. Late on Monday Mr. Elliott told me tech support "has added your domain to our permitted list".
-------- Forwarded Message -------- Subject: FW: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Mon, 15 Aug 2016 17:33:11 +0000 From: Doug Elliott To: william.whatcott, Stefan Jetchick CC: [Office Assistant to Mr. Elliott] Dear Mr. Whatcott and Mr. Jetchick: Mr. Justice Perell of the Ontario Superior Court of Justice has been assigned to be the case management judge for this matter. We have requested a case management meeting for this Thursday at 9:30 a.m. The purpose of this meeting would be to discuss scheduling for this matter. In particular, we wish to set a date when the injunction requested in our Statement of Claim will be heard. Since you are both out of province, it is possible to arrange for you to participate by conference telephone call if you wish. You are entitled to attend in person if you wish. You have both indicated to us that in principle you plan to attend Court. Can you please confirm that you are available to attend on Thursday morning at 9:30 a.m. either in person or by conference call ? Mr. Whatcott, would you please confirm that we should use this email address for you in connection with this matter. Douglas Elliott From: Elphinstone, Cindy (JUD) Sent: Monday, August 15, 2016 12:39 PM To: Doug Elliott Cc: Joan Kasozi; Nanda Singh Subject: RE: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Mr. Elliott, Please see the assignment letter in the above noted matter attached. Cindy Elphinstone Judicial Secretary Ministry of the Attorney General Superior Court of Justice 361 University Avenue Toronto, ON M5G 1T3 Email: Cindy.Elphinstone@ Tel.: (416) 327-5124 Fax: (416) 327-5417 From: Nanda Singh Sent: August-15-16 11:39 AM To: Elphinstone, Cindy (JUD) Cc: Doug Elliott; Joan Kasozi Subject: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Cindy Elphinstone Assistant to the Honourable Justice Paul M. Perell Ontario Superior Court of Justice Dear Ms. Elphinstone: Please bring the attached letter and Statement of Claim to the attention of Justice Perell. Thank you. Yours very truly Nanda Singh Nanda Singh | Phone: 416-477-7007 ext. 203 Law Clerk, Cross-Border Litigation & Business Litigation Group nsingh@
[Consecutive numbering of paragraphs added 2016-Sept-11] -------- Forwarded Message -------- Subject: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Tue, 16 Aug 2016 11:23:35 -0400 From: Stefan Jetchick To: delliott@ Cindy.Elphinstone@, Whatcott, Bill Good day Ms. Elphinstone and Mr. Elliott, (and hello also to Bill) 29. I've never been sued in my life, so I'm like Bambi on a frozen pond here! Moreover, I'm currently unemployed so unable to afford legal counsel. I do have some questions, but I'm unsure who I should direct them to. 30. Not knowing any better, I figured I'd send them to all of you. Maybe somebody can help me on Thursday during the conference call at 9h30: A) Why no Viagra for Pride's saggy security? B) Why victimize Ontario Taxpayers yet again? C) What is a law-abiding citizen to do? D) Why sue a penniless Catholic for millions, and studiously avoid suing the rich Catholic Church? A) Why no Viagra for Pride's saggy security? -------------------------------------------- 31. Why aren't the organizers of this year's Pride parade in Toronto also named in this lawsuit? 32. Every year for over a decade, I organize a small demonstration here in Quebec City, so I have a bit of experience with security during public gatherings. (See www.proviequebec.ca/en/chaine_vie.htm) 33. Never would I have tolerated the massive security breaches that we observed in Toronto. I doubt any organizer with a modicum of due diligence would have tolerated them either: 34. Full face coverings. I did not scrutinize all participants, but as far as I saw, the "Gay Zombies" were the only ones with full face coverings. (In the Province of Quebec, I think it's even **illegal** to participate in a public gathering with your face covered.) Several staff from the Parade came to see us before we started marching, but nobody ever asked to see our faces. 35. No screening of persons. We just basically walked into the parade. Out of courtesy, Bill did go see the organizers to present them some crumpled sheet of paper showing he had paid to be in the parade. There was no security cordon, no attempt to actually approve who was joining the parade, nothing. 36. No screening of handouts. Bill and the others were very obviously lugging around **very** large bags filled with stuff to hand out (since I had no idea there would be no security, I had hidden a small quantity of my own flyers in my small knapsack). Here again, several staff from the Parade came to see us before we started marching, but nobody ever asked any questions about the contents of those large bags. 37. No Code of Conduct. In the demonstration I organize, our Code of Conduct is everywhere: on our website, on paper copies handed out to participants, and printed behind **every** sign that participants hold, and the highlights of that Code are verbally repeated to the group in our little prayer meeting before the demonstration begins. (See above link for the Life Chain, Section 4) 38. Toronto Pride (at least this year, since I've never been there before) had nothing, **absolutely nothing** of the kind. How can participants be accused of not respecting an inexistant or unknown code of conduct? B) Why victimize Ontario Taxpayers yet again? --------------------------------------------- 39. From what little I understand, Mr. Elliott is trying to use the Ontario Judicial System (painfully supported by financially struggling Ontario Taxpayers) in order to compensate for the complete dereliction of duty of the Toronto Pride organizers. 40. But that cannot even theoretically work. The Ontario Judicial System could spend every last taxpayer's dollar playing whack-a-mole with Christian activists, without ever winning, if the organizers of Toronto Pride are not held accountable for their gross negligence. 41. (By the way, if even a rinky-dink demonstration organized by one Catholic guy can easily avoid all the supposedly horrible problems that the "Gay Zombies" created that day in Toronto, why am I not being hired to organize next year's Pride? Sorry, I'm unemployed, so I had to try! :-) C) What is a law-abiding citizen to do? --------------------------------------- 42. Speaking of Pride, I take pride in being a law-abiding citizen. I'm 53 years old, and I've never been in trouble with the law. So when I wrote up my flyer on homosexuality many years ago, I was very careful to stick to provable medical facts, and to avoid needless provocation (while also avoiding the other extreme, which could be called "Pope Francis obfuscation"). 43. I didn't hand out any of Mr. Whatcott's flyers (we can never agree on that topic, as his trip to Quebec City shows, many years ago. See www.inquisition.ca/corr/whatcott_bill_en.htm#s19) 44. I had my flyer checked by a lawyer, and integrated his suggestions. Also, at that time (2010) the Quebec Department of Justice had just enacted laws against "homophobia". So I sent them a copy of my flyer using registered mail, politely resquesting that they tell me if there was anything objectionable in my flyer. (See www.inquisition.ca/corr/weil_kathleen_en.htm) 45. I did get confirmation that they received my letter, but nothing else. That flyer has remained essentially unchanged since then, and has always remained very publicly on the Internet. I'm appending a copy of its contents here at the bottom of this e-mail, but you can also see the electronic version here: www.inquisition.ca/en/polit/artic/aimons_sodomites.htm 46. I admit I never thought of sending my flyer to the Ontario Minister of Justice, but I was supposed to be only a cameraman for Bill's event. A few weeks before D-Day, things started to look like I was going to myself participate, so I packed my zombie glasses and my small stock of flyers, and assumed if my flyer was good enough for the Quebec Justice Department, it would also be OK for Ontario's! 47. So yes, I admit I didn't **also** send it to the Ontario Justice Department. Is that really a million-dollar mistake? Is freedom of speech in Canada really like a field of anti-personnel mines, accessible only to the rich and famous, or to those who say only what the Ruling Classes approve? D) Why sue a penniless Catholic for millions, and studiously avoid suing the rich Catholic Church? ------------------------------------------------- 48. Common sense tells us you can't get a gallon of milk out of an Ant, and you can't get millions of dollars out of one pennyless Catholic. 49. Why go after **one** symptom, and carefully avoid the Cause? Is it because lawyers like Mr. Elliott have a vested interest in keeping a flow of profitable lawsuits, a bit like Big Pharma, which is often accused of not curing people so they can continue to sell expensive medications? 50. The Catholic Church clearly teaches hatred. Officially. Catholics MUST hate in order to go to Heaven. And I'm willing to go all the way up to the Supreme Court of Canada to prove it. 52. A few quotes with the word "hate" and its synonyms like the verbs "to detest", "abhor", "to be odious", in the Bible and the Catechism of the Catholic Church: "The fear of the LORD is to hate evil" Pr 8:13 "I abhor the assembly of evildoers and refuse to sit with the wicked." Ps 26:05 "[Don't] commit this horrible deed which I hate!" Jr 44:4 "When you begin to abhor what you have made, it is then that your good works are beginning, since you are accusing yourself of your evil works" Catechism of the Catholic Church, #1458 "Liberation in the spirit of the Gospel is incompatible with hatred of one's enemy as a person, but not with hatred of the evil that he does as an enemy. Catechism of the Catholic Church, #1933 52. (See www.inquisition.ca/corr/lemieux_lefevbre_jasmin_en.htm#s1p1) 53. I was always told that good Catholics must "Love the sinner and hate the sin", hence the title of my flyer: "Love Sodomites, Hate Sodomy!" Actually, if I look at the whole Ontario Judicial System, it seems like it's trying to "Love the criminal, but hate the crime", which is just plain common sense. 54. Is common sense now illegal in Ontario? 55. Yours truly, Stefan Jetchick [Usual full contact information] 56. Here are the contents of the only flyers I handed out at this year's Toronto Pride: ========================================================== 57. Love Sodomites! Hate Sodomy! ========================================================== 58. Lie #1: "The Church is against love between men" 59. Really? The same Church that teaches: "Love one another" [John 13:34], and "Love your enemies, do good to those who hate you, bless those who curse you, pray for those who mistreat you" [Luke 6:27-28], etc.? 60. The Church is against sodomy, not against love. 33. Lie #2: "Sodomy is perfectly natural" 61. "Anal sex is unhealthy. Aside from sexually transmitted diseases, these acts lead to many other medical conditions including the Gay Bowel Syndrome, hepatitis A, unusual infections of the epididymis, and other disorders of the anus and surrounding muscles such as fissures. Homosexuals who practice anal intercourse are as much as eighty-four times more likely to develop anal cancer than the general population. 62. Anal sex is unnatural. It obviously is traumatic to the anus, which simply is not made to accomodate the male organ. Not only does the anus have no natural lubrication, but it is clearly the wrong size for genital contact. As evidence of this, consider the difference in size of the speculum and the anoscope. The speculum, which the physician places inside the woman during a gynecologic exam, is roughly the size and shape of the erect male organ. The anoscope, used to examine the anus, is half the diameter of the speculum - more similar in size to an adult forefinger. [...]" 63. [WETZEL, Richard, MD. Sexual Wisdom, Ann Arbour, MI, Proctor Publications, 2000. chap. 10, p. 145-147] 64. Lie #3: "Homophobia is the only cause of the physical and mental health problems of sodomites" 65. First, if you define "homophobia" as being the hatred of persons with same-sex attractions, then of course "homophobia" is very evil. (See the teachings of the Church here above.) Also, if you are a person who feels hated and is contemplating suicide, please don't! God loves you! And please give us a call if we can do anything to help you. 66. But unfortunately these days, the meaning of the word "homophobia" is changing. More and more, it's just an insult thrown at people to take away their critical thinking and their freedom of speech. 67. Would sodomy have positive medical consequences if, by magic, everybody started to approve it? (See Section #2 here above.) Would babies be made differently if, by magic, everybody started to consider sodomy just as normal as what husband and wife do after marriage? Does a boy who decides to put on a dress change his chromosomes from XY into XX to become, by magic, a girl? Do our sexual attractions constitute our "identity", rather than the fact we are persons, i.e. beings endowed with intelligence and free-will? Is Quebec becoming "Science-o-phobic"? 68. Let's have the courage to seek together the truth about these questions! 69. www.jesus-eucharistie.org www.inquisition.ca
-------- Forwarded Message -------- Subject: RE: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Tue, 16 Aug 2016 18:21:09 +0000 From: Doug Elliott To: Stefan Jetchick, Cindy.Elphinstone@, Whatcott, Bill Dear Mr. Jetchick: I am not going to respond to the substantive issues that you raise in this email. I only wish to comment on two procedural points. First, Thursday's conference call is ONLY about scheduling. It is not a trial. It is not the time to discuss the merits of your case or the deficiencies of our case. If you are truly concerned about conserving costly court resources, please keep your remarks on Thursday limited to the topic at hand, namely the schedule for the case ( not the substance of the case). Second, I strongly suggest that you retain legal counsel. If you are unable to afford counsel, you may qualify for Legal Aid or for the assistance of a legal clinic. You may also find that a lawyer who is sympathetic to the importance of articulating the issues you raise will represent you on a pro bono basis. Douglas Elliott
-------- Forwarded Message -------- Subject: Re: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Wed, 17 Aug 2016 08:52:47 -0400 From: Stefan Jetchick To: Doug Elliott, Cindy.Elphinstone@, Whatcott, Bill, charles lugosi, Good day Mr. Douglas Elliott, Ms. Elphinstone, Dr. Lugosi and of course Bill, I wanted here to answer Mr. Elliott's e-mail of yesterday, but while I have everybody's attention, I also wanted to add a few housekeeping notes. First, after consulting with friends and sleeping on it, I will represent myself. Mr. Whatcott kindly offered the services of his lawyer, the famous and talented Dr. Lugosi, but even though "my client is a fool" as the saying goes, my client is also dirt poor! So I will not use the services of Dr. Lugosi. Second, I'm archiving correspondance about this case on my web site. If somebody needs my official statements about anything (not just this case), I hereby declare my web site (www.inquisition.ca) to be the reliable and authoritative source of my positions. (This hopefully will reduce paperwork and useless tree slaughtering.) Third, I will try to phone in tomorrow for the Conference Call at 9:30 AM: >> I confirm a teleconference on Thursday, August >> 18th @ 9:30 a.m. >> The call-in particulars are as follows: >> Local dial in number: 416-212-8012 Toll free dial >> in number (Canada and U.S.): 866-633-0848 >> Conference ID/Participant Access Code: [censored]# Fourth, and finally, I now respond to Mr. Elliott: >> I am not going to respond to the substantive >> issues that you raise in this email. OK, but please note that e-mail contains all the arguments I can come up with for my defense. I will simply repeat (maybe expand a bit) on those points. So you can use it to figure out your rebuttals, etc. >> Thursday's conference call is ONLY about scheduling >> [...] please keep your remarks on Thursday limited to >> [...] the schedule for the case I hereby officially declare that my position on the scheduling of this case is whatever is agreeable to Mr. Elliott. I'm unemployed, so whatever is good for him is fine by me. That way, if all goes well tomorrow, I won't even have to say anything! :-) >> I strongly suggest that you retain legal counsel. I took your wise advice very seriously, as I said above. I really do decide to represent myself. This way this lawsuit can last for decades and it won't cost me a penny. And if I lose, I have nothing to lose! (Well, you could take my 1999 Toyota Camry, which doubles in value when I fill up the gas tank!) :-) Cheers! SJJ
Form 18A, Courts of Justice Act STATEMENT OF DEFENCE ==================== Hudspeth, et al v. Whatcott, et al ---------------------------------- SCJ File No. CV-16-558424-00CP [Full names and coordinates of Defendant, Court and Plaintiff] STATEMENT OF DEFENCE -------------------- 1. The defendant admits the allegations contained in the following paragraphs of the statement of claim: 4, 6, 9, 46, 47, 50, 51, 53, 54, 57, 58, 69, 99. 2. The defendant denies the allegations contained in the following paragraphs of the statement of claim: 1 (e) to 1 (h), 1 (k) to 1 (l), 5, 20, 63, 66, 70 to 72, 76 to 87, 89 to 96. The defendant also denies the allegations contained in the following paragraphs of the statement of claim, but would admit them if the wording was changed as indicated for each paragraph: 52, if the expression "mainstream Christianity" were placed in quotes (i.e. the Bible and the Catholic Church clearly condemn sodomy, so a "Christian" who supports sodomy must first be intellectually inconsistent), 55, if the word "offensive" was replaced by "deemed offensive by some", 56, if the words "offensively anti-gay" were replaced with "deemed offensively anti-gay by some", 59, if the words "deceitfully", and "dishonest and unlawful" were struck out, and "hate speech pamphets" were replaced by "pamphlets deemed by some to be hate speech", 62, if the words "attack", "defame" and "despise" were replaced with "inform", "denounce" and "deeply disagrees with", 67, if the words "deceitfully and in bad faith" were struck out, 75, if the words "hateful, derogatory and deceitful", and the word "fundamentalist" were struck out. 88, if the word "offensive" was struck out. 3. The defendant has no knowledge in respect of the allegations contained in the following paragraphs of the statement of claim: 1 (a) to 1 (d), 1 (i) to 3, 7 to 8, 10 to 19, 21 to 45, 48 to 49, 60 to 61, 64 to 65, 68, 74, 97 to 98. 4. Table of contents: A) Housekeeping notes B) FIRST DEFENCE: The Defendant never handed out Mr. Whatcott's flyers C) SECOND DEFENCE: The only link between Mr. Whatcott's flyer and the Defendant is "Guilt by color palette" D) THIRD DEFENCE: The actions of the Plaintiff's lawyer constitute an implicit admission that the Defendant's flyer is Charter-protected free speech E) Conclusion A) Housekeeping notes --------------------- 5. Evidence. "Google is my Exhibit A", and everything discussed here can be easily found with an Internet search engine (as of this writing). Direct hyperlinks are also supplied, e.g. this Statement of Defence is at the following URL: www.inquisition.ca/corr/elliott_douglas.htm#s9 6. Timeliness. The timestamp on the Statement of Claim is 19/8/16 at 09h40, served by Mr. Denis Vanasse, Huissier de Justice. This having occured in a province other than Ontario, the Statement of Defence had to be served and filed before Sept. 28, 2016 (fourty days). 7. The "Defence E-mail". Before the hardcopy of the Statement of Claim was legally served, the Defendant had already sent an e-mail on 2016-August-16, to both the Court (via Ms. Elphinstone) and the Plaintiff's lawyer Mr. Elliott, giving, in layman's terms, most of the material facts relied on by way of defence. This will henceforth be referred to as the "Defence E-mail". The only changes made to it were to consecutively number its paragraphs, starting with the last number of this Statement of Defense. It is available electronically here: www.inquisition.ca/corr/elliott_douglas.htm#s6 8. The only other major "external" document this Statement of Defence will refer to, is the letter sent to the Canadian Minister of Families, Children and Social Development, the Honorable Jean-Yves Duclos (Liberal Party of Canada), on September 3, 2016. It is accessible electronically at this URL: www.inquisition.ca/corr/duclos_jean_yves.htm B) FIRST DEFENCE: The Defendant never handed out Mr. Whatcott's flyers ---------------------------------------------------------------------- 9. As mentioned in the "Defence E-mail", paragraphs 43 to 47, the Defendant handed out his own flyer, and not Mr. Whatcott's. The Defendant has no idea how to prove the non-existence of an act (i.e. handing out flyers he never handed out). Isn't this the burden of the Plaintiffs? 10. Even though the Defendant has no idea how to prove the non-existence of an act, nevertheless many facts point in that direction: 11. Several videos were made of flyers being handed out, showing all Gay Zombies handing out Mr. Whatcott's flyers, except the one holding the camera (and the other end of the Gay Zombie banner), i.e. the Defendant. See this URL for the links to YouTube: www.inquisition.ca/en/polit/artic/zombie_gai.htm 12. The Defendant has a longstanding and publicly documented history of refusing to hand out Mr. Whatcott's flyers, and preferring his own instead. See "Defence E-mail", paragraph 43. 13. The Defendant took pains to send his own flyer to the Quebec Minister of Justice in April 2010, to have it vetted after the "Homophobia Act" was passed. See "Defence E-mail", paragraph 44. This also points to an attachment between the Defendant and his own flyer. 14. The Defendant continues to provably disseminate his own flyer, both over the Internet and in other Pride Parades, while simultaneously telling everybody he can about his actions, ahead of time (like the Plaintiffs' lawyer, or the organizers of the Quebec City 2016 Pride parade, or the Quebec City Police Department, etc.). 15. Evidence supporting the previous paragraph is located here: www.inquisition.ca/corr/duclos_jean_yves.htm C) SECOND DEFENCE: The only link between Mr. Whatcott's flyer and the Defendant is "Guilt by color palette" ------------------------------------------------------------- 16. At issue is the link connecting the Defendant with Mr. Whatcott's flyer. Let's start with the example of a lawn maintenance company accused of spraying lawns with a chemical harmful to children. All employees of that company have signed a contract and agreed to provide the service offered by that company, i.e. spray that particular chemical and no other. But in the case of the "Gay Zombies Cannabis Consumer's Association", there is no legal entity. (Zombies don't exist, so the Toronto Pride organizers knowlingly allowed a fiction to participate in the parade.) The Defendant could not have been legally held to distribute Mr. Whatcott's flyer by something akin to a contract. 17. The Plaintiffs could argue that, despite the legal non- existence of the "Gay Zombies", nevertheless there was some form of "pact" or "informal contract" between all "Gay Zombies". Except this unwritten agreement was to get into the 2016 Toronto Pride parade, in order to hand out flyers containing facts about the medical consequences of anal coitus (technically known as "sodomy"), as well as an expression of God's love for all sinners, regardless of their sexual orientation. It did not specify which Christian flyer. This rough unwritten contract is what bound the Defendant with the other Gay Zombies. The de facto leader of the band, Mr. Bill Whatcott, celebrates diversity and is very tolerant, so the Defendant knew that the "Gay Zombies" were a very safe space to hand out his own flyers. Actually, if real members of the "LGBTQ2SI Community" with pro-sodomy flyers had showed up dressed in green, Mr. Whatcott would likely have inducted them into the "Gay Zombies" on the spot, and encouraged them to hand their flyers. (Mr. Whatcott is an ardent supporter of freedom of speech.) 18. The Plaintiffs could argue that, despite the legal non-existence of the "Gay Zombies", and despite the informal agreement between them allowing freedom of choice in the flyers handed out, nevertheless the "Gay Zombies" were still united by their common action. For example, in superbly-crafted bank robbery, each accomplice has a very definite task. They are so united by their common action, that if one single accomplice fails (for example, the driver of the getaway car stalls the engine, or the safe-cracker fails to open the safe, or the guy in charge of knocking out the security guard inside the bank forgets to check the batteries of his taser, etc.), the whole bank robbery fails. But in this case, there was no clockwork precision: a bunch of Christians just walked onto the staging area of the parade. They were seven, they could have been three or twenty-nine. The appropriate metaphor is not of a bank robbery, but of a "Pick-Your-Own" field of blueberries. A bunch of people arrive in a van and each go pick their blueberries. The work of any blueberry picker is not influenced by what another one is doing. 19. Not much remains as a link uniting the Defendant with Mr. Whatcott's flyer. Both the Defendant and Mr. Whatcott were wearing green that day. Is there really such a thing as "Guilt by color palette"? 20. The Defendant could argue in defence of Mr. Whatcott's flyer, but seeing the credentials and track records of Mr. Whatcott's lawyers, the Defendant will concentrate his meager legal abilities on defending his own flyer. If the Defendant were still asked his opinion on this matter, the Defendant would just point out that both Mr. Whatcott's and his own flyer convey essentially the same message, but that Mr. Whatcott's flyer has obviously had an unhappy childhood. (See Mr. Whatcott's autobiography available on Amazon, called "Born in a Graveyard"). D) THIRD DEFENCE: The actions of the Plaintiff's lawyer constitute an implicit admission that the Defendant's flyer is Charter-protected free speech ------------------------------------------------------- 21. The Defendant has done absolutely everything in his power, to bring the flyer he disseminated at the 2016 Toronto Pride parade, to the attention of the Plaintiff's lawyer, Mr. Elliott. The Defendant himself contacted Mr. Elliott to tell him he was one of the "Gay Zombies" (otherwise the Defendant's real name would still be unknown to the Court). The Defendant himself supplied his flyer to Mr. Elliott, as well as showing where it was publicly available on the Internet. The Defendant himself told Mr. Elliott he would continue to disseminate his flyer at other pride parades (like the one in Quebec City). 22. Despite this, the Statement of Claim never mentions the Defendant's flyer. Neither does the Statement of Claim quote passages from the the Defendant's flyer. Mr. Elliott never mentions any request to have the Defendant's flyer removed from the Internet, even though he requested that Mr. Whatcott's flyer be taken down, and even though the Defendant's flyer is very easy to find on the Internet (just type two words in Google: love sodomites). In a recent letter from Mr. Elliott (2016-Sept-09, sent to Dr. Charles Lugosi, CC to the Defendant), he again never mentions or quotes the Defendant's flyer (despite abundantly quoting from Mr. Whatcott's flyer). Mr. Elliott even matter-of- factly discusses the recent dissemination of the Defendant's flyer at the Quebec City pride parade as: "I understand that the local police addressed the issues that arose at Quebec Pride to the satisfaction of the organizers." The local police allowed the Defendant to hand out all the flyers he wanted, as long as he was on a public sidewalk and not on private property, so that seems satisfactory to Mr. Elliott. 23. These are not the actions of a lawyer who considers the Defendant's flyer as overstepping the legally justified limit on free speech identified by the Supreme Court of Canada. On the contrary, they are indicative of Plaintiffs who have no legally- defensible complaints about the Defendant's flyer. 24. Even if the Court were to overlook the Plaintiff's silence concerning the Defendant's flyer, all the Court would find is a flyer patterned after "Love the sinner, hate the sin". For example, fifty years or so ago, when the propaganda of tabacco companies was pervasive, and knowledge of the medical consequences of smoking cigarettes was rare, and assuming there had been such a thing as a "Cigarette Smoker's Pride Parade", the Gay Zombies might have handed out a flyer called "Love Smokers, Hate Smoking". Some Gay Zombies might even have included color photographs of lung cancer and other horrible diseases caused by smoking (as we can see on cigarette packs here in the Province of Quebec). 25. A cursory examination of the flyer handed out by the Defendant ("Defence E-mail", paragraphs 57 to 69) will show no graphics, and no names of Liberals or other persons, but rather a call to love members of the "LGBTQ2SI Community" (something explicitely ordered by God Himself, as the Bible quotes in that flyer show). 26. The flyer handed out by the Defendant also contains medical facts which can be ascertained by any medical doctor, or even a High School student who has taken a biology class, and who knows how to search governmental web sites, like the "Center for Disease Control" in the USA (for statistical prevalence of diseases in various populations). E) Conclusion ------------- 27. In closing, I wish to draw the Court's attention to paragraph 2 of this Statement of Defence, where the Defendant agrees (if the words "deceitfully and in bad faith" are struck out) with paragraph 67 of the Statement of Claim. This is important. Whether dressed up as a zombie with a rainbow tutu, or with a formal suit and tie, whether he is surrounded by members of the "LGBTQ2SI Community" in downtown Toronto, or surrounded by hard-core Catholics at the Latin Mass in Quebec City, whether the Defendant has entered into a contract with some organization or not, the Defendant is a Canadian, and by that very fact has already signed THE CONTRACT binding all Canadians (and all men, actually), a contract which orders us to love our neighbors, to respect all just laws, to avoid doing harm (e.g. "refrain from presenting any image or messages that would promote hatred, degradation or negative stereotyping of any persons or groups"). As opposed to many people who will read this Statement of Defence, I formally became a Canadian when I was about 16 years old. I still remember the oath I swore (in French). And if I have to die in Flanders Fields to keep that oath, then so help me God. 28. Respectfully Submitted, Stefan Jetchick [The official documents served to the Court and to the Plaintiff's lawyer have here physically included the "Defence E-mail"] RCP-E 18A (November 1, 2005)
-------- Forwarded Message -------- Subject: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Mon, 19 Sep 2016 13:04:22 -0400 From: Stefan Jetchick sjj@ To: Elliott, Douglas (Cambridge LLP) delliott@ CC: Kasozi, Joan jkasozi@, Cindy.Elphinstone@ Good day Mr. Elliott, From my limited understanding of Rules of civil procedure, 16.05 (1) (f), I can ask you if you consent to being served my Statement of Defence by e-mail. If you do not consent, obviously I would appreciate if you told me how you want it served! :-) Also, if you had any indication as to how I'm supposed to serve it to the Court, I would also appreciate. My Statement of Defence is attached to this e-mail in PDF form, with numbered pages and full addresses of recipients and sender, etc. But seeing 16.01.1 (1), here is the header of that document copied here again: Hudspeth, et al v. Whatcott, et al ---------------------------------- SCJ File No. CV-16-558424-00CP From: Stefan Jetchick, defendant (self-represented) 1450, avenue des Grands-Pins Quebec City, QC G1S 4J6 Canada 1-418-922-7015 sjj@ To: Ms. Cindy Elphinstone Assistant to the Honourable Justice Paul M. Perell Ontario Superior Court of Justice Ministry of the Attorney General Superior Court of Justice 361 University Avenue Toronto, ON M5G 1T3 Email: Cindy.Elphinstone@ Tel.: (416) 327-5124 Fax: (416) 327-5417 and Mr. R. Douglas Elliott Lawyer for the Plaintiffs Christopher Hudspeth and George Smitherman Cambridge LLP 333 Adelaide St. West Suite 400 Toronto, ON M5V 1R5 Direct: 647-430-5378 delliott@ Thank you, and have a nice day, Stefan Jetchick
-------- Forwarded Message -------- Subject: RE: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Tue, 20 Sep 2016 02:15:38 +0000 From: Doug Elliott To: Stefan Jetchick CC: Joan Kasozi, Cindy.Elphinstone@ Dear Mr. Jetchick: You can serve your Statement of Defence by email. We will consider it served today. It is not in quite the right form so I am not sure if the Court will allow you to file it. You have to file it with the Registrar of the Superior Court in Toronto with proof that you served it on us and Mr. Whatcott. Douglas Elliott
-------- Forwarded Message -------- Subject: Re: Hudspeth, et al v. Whatcott, et al; SCJ File No. CV-16-558424-00CP Date: Tue, 20 Sep 2016 10:55:08 -0400 From: Stefan Jetchick To: Doug Elliott Good day Mr. Elliott, >> You can serve your Statement of Defence by email. >> We will consider it served today. Great! Thanks to you, I finally managed to do **one** thing on my confounded TODO list! >> It is not in quite the right form so I am not sure >> if the Court will allow you to file it. Well, I guess my battle will now be with the public service bureaucrats... ;-) But seriously, do you mean this? www.ontariocourts.ca/scj/practice/practice-directions/edelivery-scj/ >> You have to file it with the Registrar of the Superior >> Court in Toronto with proof that you served it >> on us and Mr. Whatcott. I will try to figure that out. I can't find an e-mail address for them using Google. Thanks, SJJ
-------- Forwarded Message -------- Subject: Hudspeth, et al v. Whatcott, et al.; Court File No. CV-16-558424-00CP Date: Fri, 30 Sep 2016 18:29:18 -0400 From: Stefan Jetchick To: Elliott, Douglas (Cambridge LLP), Lugosi, Charles Good evening Mr. Elliott and Dr. Lugosi, Just for your information I'm re-sending you a slightly-corrected PDF of my Statement of Defence. Nothing of substance was changed. (I had made a mistake in the Court File Number, and also I tried to make the format more conformant.) The attached PDF is the version that I just printed out and sent by snail-mail to the Registrar of the Toronto court. But the old version is just as good. Cheers, Stefan
-------- Forwarded Message -------- Subject: Hudpeth et al. v. Whatcott et al. Date: Wed, 2 Nov 2016 13:55:55 +0000 From: @findlaymccarthy.com To: Stefan Jetchick Stefan: We have finalized the Motion Record and Factum. The Factum is attached. Following is the Dropbox link to the Motion Record (as it is too big.). www.dropbox.com [SJJ: I removed "../fig/corr/elliott_douglas/factum.pdf" and "../fig/corr/elliott_douglas/motion_record.pdf" from the web site 2017-March-15, because they bload the zipped file containing the whole web site. Just drop me an e-mail and I'll send them to you if you want them.] Would you please acknowledge receipt of this email. Thanks, John Findlay Findlay McCarthy PC 605 James Street North, Suite 303 Hamilton, Ontario L8L 1K1 Tel: (905) 526-8943 Fax: (905) 526-8696 CONFIDENTIALITY NOTICE This e-mail is intended only for the use of the addressee and may contain confidential information. If you are not the addressee, you are hereby notified that copying, use or dissemination of the information contained in this communication is strictly prohibited. If you receive this transmission in error, please notify the sender immediately and then permanently delete the message. PLEASE NOTE: On occasion our spam scanners may delete legitimate e-mails if there are attachments in the e- mail. If you do not receive an appropriate response please create a new e-mail message without an attachment or call the office to confirm receipt of your e-mail. Thank you.
I acknowledged receipt to Mr. Findlay, of course.
-------- Forwarded Message -------- Subject: Christopher Hudspeth et al. v. William Whatcott et al. Date: Fri, 4 Nov 2016 20:44:47 +0000 From: Belinda Wu To: charles@, findlay@, sjj@ CC: Joan Kasozi Dear Counsel: Attached please find the following documents, which are hereby served upon you pursuant to the Rules of Civil Procedure: 1. Motion Record of the Plaintiffs dated November 4, 2016; 2. Factum of the Plaintiffs dated November 4, 2016; 3. Book of Authorities of the Plaintiffs dated November 4, 2016. [SJJ: I removed "../fig/corr/elliott_douglas/2016-Nov-04/record.pdf" and "../fig/corr/elliott_douglas/2016-Nov-04/factum.pdf" and "../fig/corr/elliott_douglas/2016-Nov-04/authorities.pdf" from the web site 2017-March-15, because they bload the zipped file containing the whole web site. Just drop me an e-mail and I'll send them to you if you want them.] Hardcopies of the above-mentioned document will be couriered to you shortly. Kindly confirm service with email is acceptable. Thank you! Regards, Belinda Wu | Phone: 416-477-7007 ext. 323 Legal Assistant, Cross-Border Litigation & Business Litigation Group
I acknowledged receipt to Ms. Wu, and said I was fine with being served only electronically (I'm a tree-hugger!).
-------- Forwarded Message -------- Subject: Christopher Hudspeth et al. v. William Whatcott et al. Date: Mon, 7 Nov 2016 22:04:51 +0000 From: Nanda Singh To: SJJ@ CC: Joan Kasozi, Doug Elliott, Chris Macleod Stefan Jetchick 1450 avenue des Grands-Pins Quebec City, Québec G1S 4J6 Dear Mr. Jetchick: I enclose Ms. Kasozi's letter of today's date. Yours very truly Nanda Singh
-------- Forwarded Message -------- Subject: Re: Christopher Hudspeth et al. v. William Whatcott et al. Date: Tue, 8 Nov 2016 12:04:09 -0500 From: Stefan Jetchick To: Nanda Singh CC: Joan Kasozi , Doug Elliott, Chris Macleod Good day Ms. Joan Kasozi, Mr. Doug Elliott, Mr. Chris Macleod, Sorry for the delay in answering, at first I had no idea what your letter was about! I had to read up on Google about "Examination". If that web page is any good, it says "Consider whether to conduct the discovery by way of oral examination (R. 34) or written questions (R. 35)." Of course, if you send me written questions, that is the best solution for me. I'll be glad to answer all your written questions, probably within 48 hours. As I write this e-mail, I'm at work (we take turns in the interpretation booth, so in between turns I can answer my e-mails). Things get a bit hairy if you insist on an oral examination. Since I'm a freelance interpreter, I get translation "gigs" sporadically, and if I back out of a contract I accepted many months ago, I basically will never be called again for work. So going for one quickie oral examination would probably kill what little source of income I had remaining. And my sixty or so days of work per year are concentrated in two "bumps", two "high-seasons", and we are still riding the first of those bumps... Starting Nov. 19th (this year), I basically twiddle my thumbs and starve for several months until the next "bump" begins (usually mid-April-ish). But of course, if you "Book an appointment [...] at the law office of one of the parties", meaning my "law office" (my appartment in Quebec City), then I'm normally available any time after work (very few conferences are scheduled at night). Hope this helps, SJJ
-------- Forwarded Message -------- Subject: Attendance of Stefan Jetchick to proceedings of Hudspeth, et al v. Whatcott, et al (CV-16-558424-00CP) Date: Wed, 16 Nov 2016 17:39:47 -0500 From: Stefan Jetchick To: Cindy.Elphinstone@ CC: cmacleod@, Kasozi, Joan, Lugosi, Charles, Findlay, John Quebec City, November 16, 2016. Justice Paul M. Perell Superior Court of Justice 361 University Avenue Toronto, ON M5G 1T3 Re: Attendance of Stefan Jetchick to proceedings of Hudspeth, et al v. Whatcott, et al (CV-16-558424-00CP) Your Honor, I am a self-represented litigant in the aforementioned case. I was sitting directly in front of you yesterday (but thankfully Mr. Chris Macleod spoke for me when something related to me came up, since I probably would not have been able to utter a sound; this was my first court appearance so I was rather terrified). [SJJ: just for my information, later on that day, I was examined by Mr. Ruzbeh Hosseini and Ms. Joan Kasozi] I just wanted to say that, living in Quebec City, it would be punishingly expensive for me to come to every installment of what seems to be a long process. I guess it would be a stupendously interesting accelerated course in high-level juridical wizardry, if I were a law student. Except I'm not. I'm just a layman, waiting for "my day in court", in layman's terms. May I only attend when it's "my day in court"? (i.e. the actual part where I present my defense and confront my accusers?) Since Mr. Chris Macleod seems to magically say the things I would have said anyway, and since Dr. Charles Lugosi is a friend of my friend Bill Whatcott (the main Defendant), can I just rely on those present at all these proceedings to give me a "head's up" when I should come? Of course, I will also come any time I'm ordered to do so by the Court. Thank you very much, Stefan Jetchick [Usual full contact information]
-------- Forwarded Message -------- Subject: RE: Attendance of Stefan Jetchick to proceedings of Hudspeth, et al v. Whatcott, et al (CV-16-558424-00CP) Date: Fri, 18 Nov 2016 15:43:30 +0000 From: Elphinstone, Cindy (JUD) To: Stefan Jetchick CC: cmacleod@, Kasozi, Joan, Lugosi, Charles, Findlay, John Mr. Jetchick, Please see letter of today's date from Justice Perell attached. Cindy Elphinstone Judicial Secretary [etc.]
-------- Forwarded Message -------- Subject: Letter from Doug Elliott Date: Thu, 19 Jan 2017 10:03:07 -0500 From: Joan Kasozi To: sjj@ Dear Mr. Jetchick: Please see attached letter from Mr. Elliott Best, Joan Kasozi [MS-Word document original here, copy-pasted below] January 16, 2017 WITHOUT PREJUDICE R. Douglas Elliott, 647.430.5378 (Direct Line) delliott (at sign) cambridgellp.com Stefan Jetchick 1450, avenue des Grands-Pins Québec, QC G1S 4J6 Canada Dear Mr. Jetchick Re: Christopher Hudspeth et al. v. William Whatcott et al. Court File No.: CV-16-558424-00-CP Our File No.: 1602326 Upon review of your Statement of Defence and the transcript of your cross-examination, we have concluded that we will no longer continue with you as a defendant in this action. The main reason for our decision to exclude you from this action is that you did not distribute the impugned literature that is at the centre of this dispute. We have reviewed the literature that you distributed and we agree that the overall content and tone of the pamphlet does not contain the same hateful message as the literature that Mr. Whatcott and the other Gay Zombies distributed. Moreover, there is no defamation contained in your material. We take note of the fact that although you agree with Mr. Whatcott's general message, you do not agree with the manner in which he conveys his message and some of the general beliefs he promulgated in his literature. Further, we do appreciate the fact that you did not fill out the initial deceptive application to participate in the Pride Parade. We understand that we do have a claim against you for (1) concealing your identity in order to obtain admission to march in the Pride Parade (2) breaching the Pride Parade Rules by failing to forward your pamphlets to Pride Toronto for pre-approval and for (3) distributing a pamphlet that was not in line with the Pride Toronto theme. However, since our claims of defamation and intentional infliction of mental distress do not apply to the literature you distributed, we have decided that it is no longer necessary or appropriate to pursue this action against you. We will be so advising Justice Perell. Yours very truly, CAMBRIDGE LLP Per: R. DOUGLAS ELLIOTT RDE/bw Copy: Charles Lugosi [www.lugosi-law.com] John Findlay [www.findlaymccarthy.com]
-------- Forwarded Message -------- Subject: Voluntary dismissal of action? Date: Mon, 23 Jan 2017 12:59:35 -0500 From: Stefan Jetchick To: Elliott, Douglas CC: Lugosi, Charles, Findlay, John, Kasozi, Joan Quebec City, January 21, 2017. Mr. R. Douglas Elliott Cambridge LLP 333 Adelaide St. West Suite 400 Toronto, ON M5V 1R5 Direct: 647-430-5378 delliott (at sign) cambridgellp.com Re: Christopher Hudspeth et al. v. William Whatcott et al. Court File No.: CV-16-558424-00-CP Your File No.: 1602326 Good day Mr. R. Douglas Elliott, I received your letter dated January 16, 2017. I wanted to thank you kindly for your professionalism and courtesy, and also wanted to ask you how exactly you propose to dispose of the pending claims. Yours very truly, Stefan Jetchick [Usual full contact information]
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