is: pi. - 13H13I3314 33: 33 13333333333 E33333 333E 31333 ONTARIO I . - 5 a Supermr Court ?of Justrce PM MP ?Fair Ell, mg, 3333559 anbnto ?fl/u 31 I. ?35mm: Gialrm Guurt Claim ND- a. 3 i1 aneppard Avenue East, - cm MEN if}; giddr?a 3 3 3 3* 413-323-3554 . k? a. 1? Phom umber Plaintiff Na. 1 matrianaa 333335: 53:33 on mm Form 1A. Under 13 yam.- gram. Last narni. ur name of WNW LEHHEH Final mm. Sen-um! name Alan Imam-m as ANDY . War unit) -- DHTARIO Postal 001103 LEUCW Aride (w umber. apt. unit} immune Phone nu. Poalul and: Fax nu. mm. No. Adamgnai defendan?s) llama an attanhert Farm 1A Undar 13 year: M393. Last ?at?rvar our name of company RMRKE First name Banana! name Alan known 35 TIM Adm-w: street number. malt) ?iyrruwn Pmumna [E'hnne no. TORONTO DHTAHID Pasta! ewe ax no. Rapresanta?va Lama: Addmuu {Want rumba: wt. unit} Emrl'um Pru?nm Phonl no. nude Fm: m. L33 furmules des tribunaux son?s af?ch?es an anglais at an frangais sur la site Visitaz 33 site pour des r3n33 gnamants sur des fonnats amassiblas. 3m topmumurg 33. 3314) G60 3mm 33mm- lEr?lEr?EEl-? 88:38 ONTARIO Buperinr Crawl: of Justina PAGE 1A Additional Parties ann TA Dnt. Reg. No; 258.533 . I claim ND. Plaintiff No. Defendant No. 2 Lnat harm, er name of nnmpany EASY DHS INCL First name Seannd name - Aim new as EABYWEB murmur (mm rumba. up!" unit) EMA-219 BUFFERIN STREET . m, Gity?'uwn Province F'hnne nn. GNTARICI Postal nude Fax no. M6 5Q 1&1-433-5221 Rapmanmtiw Leuca Addreaa (sire-e: nunba'. ant. unit) Provinne Phana no- Pam! man Fax nu. I'j Plaintiff No. E3 Defend-am Ne. Last name. or name if mmpany ?rm? name Seennd name N5: 35 Andrea: [ah-ant number. apt. unit) GWEDM Fromm PMM no. Fiesta] nude Fax n0. ??apmneuva LEUINF Adams: {mat mat" wait) Wow Provinne Phone no- Postal code Fax no. Piaintl?? No. Dafnndant Na. Laat name, or name Df annipany Fitat name Second name Alan mm :35 Address {street number. apt. m5 vainne Phone no. I Pnatal nude Fax no. A Raprasma?va Lama Ardde (strum apt. Unit) Gityfl'a-wn Province I I Phone no- _h Postal code: Fax no. 2014) can 1251852814 88:38 83HE8 FORM TA PAGE 2 Claim ND. REASONS (:me AND DETAILE Explain what happened, Includan where and when. Then explain how much money you are claiming er what gnnde yen want returned. If ynu are relying an any deeuments. yeu MUST attach canine tn the claim. If evidence is luster unavailable, yeu MUET explain why it ie not attached. What happened? (BEE PAGE 4) Where? When? 56R ?.Dl-m (January 23. 3014143513 on next PHBB 1251852814 88:38 84HE8 PAGE: . FORM ?t I mm 9 much? meetings) I I . ADDITIONAL mess ARE must-lee seems: MORE seen was messes. The plaintiff else elelms ere-judgment Interest'frem Matt 7. 2514'. . under: {?ats} l- (mm my the Courts efJus?agreement st the rate of ti. per yes:- and pest-judgment interest. and eeurt Ieests. Prepared an: August 7 20 14 All? l} tillt a Issued en: . - ?mmSeru1se (sentim- IDN YDU DO NQT FILE A DEFEN arm SEFENDANT: the court within twenty (20) calender after yeu have been served Witt-unis Plaintr??sl. I .. Claim, judgment mag} be slammed witheut Mine and enforced against yen- Farms. endlself- - gI - . help materials are available at the 5mm! claims Ceurt and en ?le-foilean websites - Ema. For infennstiort an accessibility of court services fer - I. I pseple with; needs, contact: - Telephone: TTY: sea tam-m (January 23. 2014) est; 1251852814 EH: SE FORM FORMULE Giafm Me. I do to demands PAGE 4 On or about May 7, 2014, I learned that on or about April 27. 2014, harassing, defamatory and iibeilous statements about me had been posted on the internet on a website owned by the Defendant, Tim Rourke ("Rourke"), and hostedby the Defendant, Technologies inc. at the following Uniform Resource Locator (URL) pages: a) (hereafter referred to as ?Webpage 1.. . b) (hereafter referred to as "Webpage 2" c} (hereafter referred to as "Webpage The aforementioned pages. aion with the entire site located at and several other domain owned by Rourke had previously been heated by the intemet provider HostPapa ice, but had been removed from the intemet by HostPapa Inc. on or about March 13, 2014. apparently due to violations by the website content of the company's tam-is of servloe agreement with Rourke From approximately April 2013 until February 2014, the pages in question had been hosted by the Internet service provider Fused until the site was suspended, . apparently due to violations by Rourke of the company's terms of service agreement. Notices of Libel pursuant to the Libel and Slander Act, RED. 1990, c. L. 12 were served on or about May 1, 2014, on Rourke and demanding the removal of the defamatory material outlined below! Rourke did not reply, though delivery of the notice was confirmed by his signature. Mark E. Jeftovic. Chief Executive Officer of Easy DNS, replied refusing to remove the material claiming that ?Whether the content is defamatory or not is a dispute between you and the customer and a matter for the courts? and denying any legal responsibility for the contents of the website. 5) Rourke has been engaging in a oyberbullying, harassment and online defamation campaign against various individuals and organizations for over a decade. Most of his son Les-1Mde 7.21114; name-2014mm 1231832814 88:88 FORM I FORMULE 7A 3) 7) 8EIE8 PAGE 5 Claim Nomi? do is demands attention has been directed at a non-pro?t tenant association, the Federation of Metro Tenants Associations and its current and former staff and board members. Rourke was a member of the FMTA's board of directors until approximately 2000 when he was booed from the organization for allegedly physically attacking another board member. Since that time, Rourke has vindictively engaged in a campaign of harassment, vill?cation and defamation against the FMTA, Its staff, board and volunteers. Approximately ten years ago, Rourke established a website attacking the organization and numerous individuals involved with it by name on a now defunct website which was located at URL in 2000, Rourke added a gallery consisting of images of individuals involved with the FMTA and short descriptions of them, many of which defamatory or othenlviee unflattering and insulting. The gallery in question is now located at the URL Also in 2009, Rourke created the "Cause Pimps? website which was devoted to lengthier defamatory attacks of a personal nature against individuals involved with the FMTA as well as other individuals and organizations. mostly anti?poverty and community activists, which Rourke wished to villfy. i was elected to the FMTA's board in or around June 2000 and became its vicechair shortly thereafter and remained on the board until November 25, 2009, when i resigned as commitments on another board i was serving on concurrently did not allow me enough time to devote to the FMTA. At about the same time, i was added to the gallery on Rourke's anti- FMTA webpage and a page attacking me was created by Rourke on his "Cause Pimps" website. in August 2010, Webpage 1 was removed from the Google web search engine due to copyright violations. Specifically. Rourke had illicitly used a photograph of me that had been created by a friend of mine at his house. A copy was made without permission from my friend?s Faceka page and used by Rourke on his website. Rourke subsequently retaliated by creating Webpage 2, Webpage 3. and various other pages under the subdomain DEFAMATDRY AND LIBELLDUB STATEMENTS see (January 7, 1251852814 88:38 8TUE8 FDRM FORMULE 7A PAGE 6 .. Claim No. de la demands 3) The intention of these pages is to maliciously harass and defame me in order to injure my reputation. The pages make various false allegations that are defamatory under the Libel and Slander Act (Ontario) 1990, CHAPTER L12) and common law. The pages also constitute tortuous harassment of me. 9) Below. I have noted some of the more malicious. libeilous and defamatory comments published on your websites. If I am forced to file suit to stop your wrongful conduct, I will also seek an award of his legal costs on a substantial indemnity basis. The malicious. libelous and defamatory material includes I A) Webpage 10) Falser claims that I am a ?Forex trader" or a "tout or bird dog". In fact I have never been a Forex trader and have never advised anyone or undertaken any advocacy in regards to foreign exchange trades. 11) lnconectiy states that was "co-chair? of the Federation of Metro Tenants' Associations and falsely claims that from that position saying it was necessary so the FMTA wouldn't be found responsible for artist he is going to do? In fact I never said any such thing. The suggestion that I left to evade some sort of responsibility for some sort of action is false and defamatory. 12) Falser claimed that "headfedl up? a group that "took over? CKLN Ftadlo and falsely claims that I wanted to ?give a very large timeslot on CKLN to FMTA and other extremist groups." I did not advocate the awarding of any timesiots to FMTA or ?extremist groups? and, in fact, the FMTA did not have a timeth on CKLN during my period on the GKLN Board. The suggestion that i used my position on Board in this way is false and defamatory. 13) in regards to the St. James Town Residents Association. falsely claims that I was not a tenant in at. James Town in 2007 when NOW Magazine published an article on the association. The suggestion that I lied or misrepresented my residency is false and defamatory. MINA (Jammy 2014; mower 20m GED lEr?lEr?EEl-il 88:38 F'r'llEE .1 I ?ll-u pennant-unn- cfaim No. do to demands 14) Feieely claims that i have participated in ?interest harassment campaigns.? 15) The page fatser claims that Michael Laser and myself made a bogus claim of copyright violation in order to have an earlier version of Webpege 1 removed from Google?s index. in fact, the version of that page at the time of my complaint included a picture of me which had been cropped from a picture on Michael Lester's Facebooit page which you used without permission from Mr. Letter or myself. As the picture was owned by Mr. Laser the claim that Mr. Rourke had violated his copyright was entirely correct. to) The page falser claims that I placed an ad on Kijiji ?adVeriising [my] services to attack other people's web sites.? The advertisement was actually placed by an impoeter and as soon as was informed of its existence by a third party I contacted Kijiji to complain and they removed it immediately the following page is veri?cation of this: since I informed you that it was false. B) Wehpage 2 in regards to my being arrested at a demonstration outside the Royal Ontario Museum in June 1990. the page falsely stems: "but as usual his charges are dropped, but not most of the others. After all the repeated raids and arrests since he joined. the activists get suspicious and kick him out of the group.? defamatory. The charges against nine out of eleven individuals were withdrawn; a tetlth individual was acquitted due. in part, to testimony I gave as a defence witness. I was not a member of the committee that organised the demonstration and was not suspected by or barred from any such organization. Nor was the organization every subject to "raids". The claims made by you are false and malicious. 13) In another portion of the page Ftoultte falsely and maliciously states: sea (January 7. 2th 4! Tender 2014) can 1251852814 88:38 88HE8 8 Jill; I I Giana Na, {N?deil dismantle "Andy is quite at home back in Toronto, with his new name. and his past history, mace and suspicions about him being a paid operative for the authorities against the Mumia organizers all forgotten.? This statement is false and defamatoryi i was never an operative, paid or otherwise ?for the authorities against the Mumia organisers? nor did any "Mumia organizers? or organizers of the 1990 demonstration at the Royal Ontario Museum ever have any soch suspicions. 19) In regards to Anti-Racist Action, the page falser states: ?Mick from ARA blames Andre-Andy for the breakup of the original group citing that Andy insisted on being their researcher but about 1:3 of the people he claimed were nee-Nazis and sent ARA after were anything but, they were only Andy's personal enemies." This statement is false and defamatory I was not a member of Anti-Racist Action in the 1990s or when any individual named ?Mick? was a member and was not involved in any way with the ?breakup of the original group". nor was I ever the organization's "researcher", nor did lever claim that my ?personal enemies? were nee-Nazis. 20) Further the page claims: ?Andre. now known as Andy is much happier with the newARA run by Shane il/iartineaI because Andy says Shane doesn't ?hold back" like the old ARA didl." This statement is false and defamatory: have never said any such thing. 21) In regards to Queen's University and the Canadian Federation of Students (CFS) the page falser states: "Andre boasts he ls being sent to Kingston to enroll at Queen?s University and it is all going to be paid for by the Canadian Federation of Etudente." SCH tan-in laundry 7. 2014! rm 2014]: can 1231832814 88:88 FDRM FDRMULE IVA PAGE 9 Claim No. I dc to demands This statement is false and defamatory. A). I was not ?sent to" Queen's University by-the Canadian Federation of Students: 9} have never been offered nor received any payment. whatsoever by the Canadian Federation of Students, C) have never made any such claim or boast. 22) The page falsely claims: "(line of Andre's first actions as at Queen's University student is to start a $500,900 lawsuit against the OUSA student union to bring it down to allow a CFS takeover." This statement is misleading and defamatory. In early 1996. led a successful campaign for the Alma Mater Society of Queen's University to leave the Ontario Undergraduate Stadents Alliance (CUBA). Subsequently, DUSA then ?led a frivolous and vexetious lawsuit against me and, in late 1996, I filed a countersuit against DUSA. Both parties agreed to withdraw our respective lawsuits without any monies being paid by either party. The Canadian Federation of Students had no involvement. whatsoever, with the lawsuit. was not involved with any attempt to have Queen's University join the CFS. nor was any such move attempted. The suggestion that attended Queen?s University in order to file such a lawsuit or that my legal action had anything to do with the CFS is false and defamatory. 23) The page falsely and maliciously claims: "With his only gainful employment in thirty years being in Kingston as taxicab driver? This statement is false, malicious and defamatory. i had several years of ?gainful employment" at various companies prior to my 30?? birthday. 24) The page states: ?if you don't include the tuition paid for by the CFE for breaking the ancumbent [sic] student organization" see ins-tn (January 7. ?janvfer 2014} can 1251852814 88:38 11HE8 Claim No. Hf? de la mm This statement is false and defamatory. As stated previously 'l was never offered nor glven payment by the Canadian Federation of Students in any way, either directory or though the payment of my tuition. 25) ?or any money he may have received in Toronto from the Intelligence Squad,? This statement ls false and defan1atory. I have never worked for nor received any payment from the Toronto Police Service or its ?Intelligence Squad". 23) The page falsely and maliciously claims: "Andy gets a part time contract at George Brown assisting disabled students but the contract isn't renewed. because Andy is up to his old tricks of setting people aginst each others [sic] in the hopes of securing power and a full time position for himseif. Almost a decade later Andy is still using the nanative that he helps disabled students, though he only did that for a year a long time ago and George Brown didn't want him nor did the students.? The only true part of the above statement is that I have worked for George Brown Gollege In this capacity. The rest of the paragraph is utterly false, defamatory and malicious and designed to hurt my employability. 27) In regards to my residency in the St James Town neighbourhood in 2007, the page falsely states: "Andy living in his tony Bay Street condominium with ccnceirge. [sic] under the false claim of living in the impoverished St- Jamestown neighbourhood. create the ?ctional St. James Town Residents Association, as a means of getting income from fake memberships. He even gets a story in NOW magazine because they don't verify his Story.? ace were [January 3014! Heavier act-i} GED 1251852814 88:38 12f28 FORM I FORMULE TA PAGE 11 .. {Helm No. I do (I demands This statement is fates and defamatory. In fact, I Was a tenant in an apartment at 260 Weileeiey Street East in St. James Town for several years, Including in 200? when the St. James Town Residents Association was created and at the time of the NOW magazine article- The suggestion that the association was created "as a means of getting income from fake memberships? is uttedy false and defamatory. There was no membership fee, nor were any donations either solicited or received. 28) The page makes the following false and defamatory statement: ?Behveen flogging his Soclallst Worker newspapers for Socialist Alternative at events, where Federation of Metro Tenants? Associations hack, and Communist Party of Canada organizer, since 1990, Howard Tessier is flogging their publication People?s Voice, and their meeting up at Communist Party of Canada meetings and both trying to get funding from pimping the story of the poor people of St. Jamestown. The 2 iikeminded people get connected and Andy gets interested in the FMTA, becoming {So?Chair in 2009. At ?rst Howard said Andy was his ?perfect weapon? ceiling Andy a "sociopath"." In fact, I have never met Mr. Tessler at a meeting of the Communist Party of Gar-lads and, in fact, never met him or had any knowledge of him prior to my joining the board of the Federation of Metro Tenants? Associations in mid-2003. Mr. Tessler he no involvement in my joining the FMTA and has never referred to me In the way suggested above. Further, the "perfect weapon" and ?sociopath? statements are false and defamatory in the extreme. 291The page makes the following false and defamatory statement: ?Andy even got another Job this time at Seneca College, thanks to his Socialist Party of Ontario cohort Andrew Kiochek?s father who teaches there. but even that connection could not get his contract rat-revved with all the chaos Andy created between the This statement is false and defamatory. in fact I have never been an employee of Seneca Collage, do not know and have never met Andrew Klocheok?s father and, consequently, EUR 7. 2014} Tjanwsr 2014) 03D 1251852814 88:38 13HE8 FORM 71! PAGE 12 .. Claim No. do Is demande- Professor chchek has never attempted to aid me in obtaining employment. The claim that I "could not get [my] contract renewed" is false as have never had a contract with Seneca College and the claim that 1 caused "chaos" bemoan personnel is utterly false and defamatory. 30) in regards to the Ontario Health Coalition,- you make the following false, defamatory and malicious statements: "Andy was certain the 0H0 would be his ticket to money and power. He stole most of his brilliant ideas from 2 seniors on the group and worked his way up to President on their coattails." In fact i never "stole" any ideas and have never been, nor claimed to be, nor sought to be, a member of the Ontario Heaith Coalition's governing body iet alone President. Nor did i ever view the DHC as my ?ticket to money and power." These claims are utterly false, malicious and defamatory. ?On October 6, 2003, the OHC released the report Eroding Public Medicare. As President of the 0H0. Andy did some minor editing of the report, which included thanking himself ?rst as a "researcher" on the report when he was not at all involved in the detailed work.? This is false and defamatory. The report was written and edited by the Director using research provided by myseif and other individuals who were acknoiniledged in the report. ?The Ontario Federation of Labour, the group behind the OHC, had enough, and not to cause a scandal to reveal Lehreri fraud, pushed Andy out the door, but Andy still markets himself as a ?rsseecher?Tsicl using this report." This statement is false and defamatory. There was no ?fraud?, nor was there any complaint by the Ontario Federation of LaboLir or any other source about my work, nor was i the door? Your claim is an utterly false, defamatory and malicious fabrication Eff-fl tub-Ht (Jammy 7.2014(1an 20H) GiiD 1251852814 88:38 1 if 4 28 FORM I FDRMULE 7A PAGE 13 .. Claim lilo. do in demmde designed to hurt my employebility. Also false and defamatory is your olaim in another part of I your page that ?Andy uses his name on others work on that one Ontario Health Coalition report to claim he is a researcher." 31) in the paragraph titled "Ontario ?lanai-its" you make the following false and malicious statements: "Howard Tessler of the Federation of Metro Tenants Associations, brought Andy onto the board of the group in 2008, only for Andy to maneuver himself to (Io?chair." Mr. Tessier had no role in my joining the nor its board. Nor was i ever the FMTA's "oo-oheir". "Tessler wanted that the person he calls a 'soolopath' and a ?great weapon" was going to take over the group." Mr. easier has never said any such thing and the claims wroneg attributed to him are false and defamatory. "in an effort to redirect him. Tessler got him to target a disabled men involved in tenant issues for about a oentury who runs the most popular tenant website in Canada saying that Andy oouid easily harass him into giving up over a deoedee worth of work to them. Whether or not Tessler came up with the Idea, Andy has been getting more people involved by saying he has million in grants lined up if he can get control of the website and if others will help they will get great paying jobs for getting involved in the harassment. With foolish people desperate for money one son bet he has found little problems getting more involved in the soheme. They drove that tenant webmaster off of Facebook and it looks like the guy is going to wimp out after years of harassment and sell his website to put an end to all the problems. Andy is oertain that this is an easy way to fame and fortune - taking over someone else's work. just as he did-at the son main (January 7. mm Heavier sore) oso 1231832814 88:88 15e?28 I Claim NoJN?dei'ademande This statement is malicious, defamatory and utterly false. 1 have never made the statements attributed to me, have never had any interest in obtaining someone else's website for myself or anyone else, and have never attempted to recruit anyone to get control of or purchase such a website. Nor have I ever attempted to "take over someone else?s wontthe GHQ. 32) In regards to the statements you make about OKLN Radio loco ?There is no better way to destroy any organization that to let Andy get Involved" and that and people from DCAP were responsible for a "takeover" of the CKLN Board and subsequently "destroyed the radio station and stripped it of all its assets" - these statements are defamatory, misleading and a distortion of actual events. 33) In regards to ?No One Is Iilegai" and the claim that: "Andy pushed forthe creation of a Roma Sanctuary Committee. He promised a network of churches and safe houses to provide sanctuary to i0,000 Roma refugees to keep them hidden from Citizenship and immigration Canada, but most of his efforts went towards fundraising for this cause. What if any money was raised and where it all went ls anybost guess or was it all talk and no action out of Andy? Unless Andyi'Andre Bratu Lehrer gets others to do all the work, little ever gets accomplished other than talk and disruption." have never advocated the creation of nor been involved With any ?Roma Sanctuary Committee? in any way, nor did i ever promise "a network of churches and safe houses to provide sanctuary to 10,000 Roma refugees to keep them hidden from Citizenship and immigration Canada" nor was i ever involved with any fundraising, nor receive any funds, for such a purpose. The statements made by you are false, defamatory and malicious. 34) The paragraph titled "Who's next? is false, defamatory and malicious in particular the claim that i target "the dying, unaware students, the disabled and seniors, whether it was in Toronto or Kingston." This statement is libelous and defamatory i have never ciaimed nor SCH 1.05-1A {January 7, 2014! Heath-arm?) GED 1251852814 88:38 18HE8 FORM TA PAGE 15 .. GIeim No. I do In demands boasted that i "can take down any opponent?, I have never claimed to have "almost 100 email accounts" to ?le complaints, 35} The page falsely claims that I was "Co-chair? of an organization called the FMTA (Federation of Metro Tenants Associations). I have never had this title. "Your statement further claims that I left the FMTA board in order to evade some unspeci?ed "responsibility" and that I continue to be very active with them In fact. I left the board in late 2009 due to other commitments and not to evade any sort of responsibility. My only involvement with the FMTA since then was to attend the 2011 Annual General Meeting. The claims made on the webpage are false and defamatory and are made maliciously. 36) The page also detainee me by claiming that I use or have used CKLN Radio as a ?power base" and that i "wanted to give a very large timeslot on CKLN to and other extremist groups." This statement is libelous and defamatory. This statement is expressly false as neither FMTA nor any other supposed "extremist" group has been offered a timeslot by me and. in feet, FMTA has and has had no tlrneslot during my time on the board. I was duly elected to the board of clin of GKLN Radio Inc. on July 24, 2009, and did not know the other board members at the time of my election. I subsequently became the board?s secretary and later vice?chair: The claim that my election was Improper or that I led a group that took over the station is false and defamatory. 37) The page also claims: "Andy boasts he can take down any opponent and has kept it up a decade in at least one case. He brags about having almost 100 email accounts he uses to file complaints, to get people's email accounts. Facebook pages and Twitter accounts cancelled and can delete anybody?s links on Wildpedla and get anybody who Is willing to pay their own Wlkipedla page that will remain up with the help of his "socialist conta have made no such boasts. The claim that I have "hundreds" of email addresses is false and the paragraph malicioust defames me by claiming that manipulate the content of sea 1-13am (January 7, 2014: Tjenvfer sow} cso 1251852814 88:38 lif28 I I lli?lrl-IHH Giaim Halli? deiademande social networking and other sites. This and other similar statements made on the page-are malicious. false and defamatory. Furthermore, I have never made or offered to make edits to Wiitipedia for pay. 33) The following paragraph is utterly false and defamatory: ?If you get an email from Andy or anybody you suspect to be him or one of his supporters DO NOT RESPOND. There are 2 reasons for this. If you see a massage is strange. doesn't make sense or makes false accusations, particularly accusations that you think Andy is guilty of commiting [sic] against you but he is accusing you of doin to him, he is usually blind copying the email to other people to create a fake paper trail of evidence. or to get other people to believe you are guilty of this to get them involved in helping him against you. Andy also wants a response to selectively quote and to take the headers from so he can take postings from you. DO MDT I do not ?iake postings" from people, i don't blind copy or create ?fake paper trail(s) of evidence", malts false accusations and so on. 39) in regards to the section on the Socialist Party of Ontario: The claim that i said the following in regards to Joe Flexer's death: "it was about time that old bastard crooked!" is an utterly raise, malicious and defamatory fabrication. i have never said any such thing. Furthermore. Michael Latter never referred to me as a ?master manipulator? and have never said ?Goebbels was an amatenr compared to me", have never referred to anyone as "that fucking gimp" and never said "2 old bitches at the OHG were going to pay" or words to that effect. The quotations are complete fabrications and your attributions of the latter three to me is defamatory and malicious. The claim that I used Michael Laser to make false copyright claims in regards to your pages is false, libelous and defamatory. The copyright claim was valid and upheld by Google as the image in ouestion was taken by Mr. Lester on the back deck of the house he was then residing in. SEE 1.05M [Jillime 7, 2014i 2014) G50 1251852814 88:38 18HE8 . Claim No. do I: dot-risotto 40} The claim that: "Another example of manipulating others to take the risks for him, was the two women he got to make and second his motion to decharter GKLN so he could never get the blame.? The women were in fact the Chair and Vice-chair of the GKLN board and were acting upon a decision by the board to seek dissolution as a result of CKLN's loss of licence. 41) The claims that I "plant false .intonnatlon" or "falsi?ed history" ls false and defamatory. i3) Webpage 3. 42) This page falsely states that: "Lehrer was a primary source of false intelligence to ARA about who was a racist who should be attacked. Many were just people who somebody wanted attacked; somebody within the radical left attack machine within which Lehrer is an operative.? This statement is utterly false and defamatory. gave no intelligence to ARA, false or otherwise. about who ?should be attacked?. 43) The statements made In the aforementioned webpages that you host are untrue, unjustified and dc violence to my personal and professional reputation. I demand that these unfounded allegations and the page on which they appear be removed immediately and that you cease and desist from harassing me onlina. MALICE, HARASSMENT AND DAMAGES 44) The Plaintiff pleads that the Defendants acted maliciously in mat: a. After a notice of libel was sent to the Defendants, they continued to post defamatory materials. Speci?cally. Webpage 'i was expanded in salty June 2014 with material attempting to intimidate the Plaintiff by listing several of the Friends listed In my Google+ webpage: b. The Defendants have not. as of this date. removed any of the Postings: BER 1.05-1A (January 7. 2014! TIEnvi'Br' 038 1251852814 88:38 18HE8 FGRM FDRMULE 7A PAGE 1 -. claim No. I do is Hernando c. The Defendants have not, as ofthis date, retracted the Postings andior apologized to the Plaintiff for having defamed him 45) The Plaintiff pleads that as a result of the Postings. his personal and professional reputation have suffered; the Plalntiff has been brought into ridicule, scandal and oontempt both personally and professionally; the Plaintiffs livelihood has been threatened; and the Plaintiff has suffered damages. 46) The Plaintiff states that the conduct of the Elefendants towards him has been malicious, reckless and reprehensible and in complete and total disregard for his personal and professional reputation and that such conduct warrants the imposition of aggravated and punitive damages. 47?) The Plaintiff pleads and relies on the Libel and Slander Act. RED. 199i], o?L.12. and on the civil tort of defamation. 43) The Plaintiff pleads and relies on Rule 1(2) of the Clntado Rates of the Small Gfaims Court 0. Reg. 258198. r. 1.01., the Courts ofJustfoe Act, FLSD. 1990, c. (3-43, as amended, and more speci?cally on Rule 1.05 of the Ontario Rules of Civil Procedure RED. 1990, Reg. 194 as amended. to obtain an order from this Honorable Court the Defendants to have the Postings removed from the websites and to post a full retraction with as much clarity and prominence as the defamatory and libelous words spoken andfor written andior published. 49) Several of these pages appear, or have appeared, on the ?rst page of resolts when my name is entered into Googls and thus has caused harm to me and hold the potential to cease ongoing harm to my reputation. 50) Rourke's defamatory webpages have been widely promoted on the internet by links to them being posted on the comment sections of various blogs and by being listed in various intemet directories. possibly by Rourke himself. These actions aggravate the damage to the Plaintiff. As of January 6, 2012 the aforementioned defamatory web pages continue to be broadcast on the lnternet. 49) The Plaintiff states that the Defendants are liable to him for all damages flowing from the defamatory words as set out hereln. Loses (January 1. 2pm Henderson) cso lEflEfEEl-ii 88:38 F'i'ltEE TA PAGE 19 Giana 50) The Plaintiff states that by the publication of the words as set out herein. his reputation has been seriously prejudiced and his integrity has been impunerl. The Plaintiff has been held up to ridicule and contempt as a result of the actions of the Defendants as set out in this statement of claim. 51) The Plaintiff further states that the conduct ofthe Defendants constitutes harassment. in particular, the defendant Rourke has aggressively promoted the defamatory pages on the intemet, causing links to the defamatory pages to be posted in various locations on the internet including in the comment sections of various web logs (?binge?), comment sections of news articles and other locations and by republishing the comments after they have been removed by his previous lnternet Service Providers and also causing the comment to be republished on other websites. The behaviour of the Defendant has caused the Plaintiff to be fearful of physical and otherfonns of harm. The behaviour of the Defendant to target friends and associates of the Plaintiff has caused strain to his personal relationships and his ability to establish futons social refetionahips. 52) The Plaintiff further states that the conduct of the Defendants in their failure to properly. or at all. ascertain correct information prior to publication of the libels set out in this statement of claim acted in a- callous and high-handed matter and that their conduct should attract the censure of the court. The Plaintiff therefore seeks punitive damages. ace mam {January sum mm aria cab