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MARCELLA'S DEFENCE 8:

The Defendant submits that the Plaintiff initiated numerous specious harassing 911 calls that speciously directed the police to the Defendant's home.

REPLY 8.

At least one of the 911 calls initiated by the Plaintiff was credited to the Plaintiff's Mom as having saved her life before the Plaintiff had been evicted against the wishes of his Mom. The 911 calls were made out of safety concerns for the Plaintiff's Mom based upon reports made by neighbours to the Plaintiff that Horace Carby-Samuels continued to neglect the Plaintiff's Mom.

When the Plaintiff finally saw his Mom having lost the ability to speak and write and smelling like fecal matter, it is apparent that these 911 calls were very justified based upon 'before' and 'after' photographic evidence.

MARCELLA'S [and her father's] DEFENCE 9:

For a while the Plaintiff has stopped the numerous calls and harassment, however, he appears not to have found himself another way to carry on the 'harassment' by filing a vexatious legal action.

REPLY 9.

The Defendants use of the term “harassment” is simply a code word for attempts by the Plaintiff to contact his Mom and to protect her from a pattern of abuse and neglect that the Defendant have subjected the Plaintiff and his Mom.

MARCELLA'S [and her father's] DEFENCE 10:

Further, the defendant pleads that the Plaintiff went so far as to attend to court and swear a declaration which claimed that the Defendant Horace Carby-Samuels was insane; thereby compelling the police to take the Defendant to be medically tested at the hospital late one night.

EDITORIAL NOTE: At least one witness complained that Horace kept ranting about “demons” and other witnesses complained of hostile and violent interactions that appeared to be irrational behaviour.

One neighbour who visited 30 Jarlan Terrace had complained to the Plaintiff that he saw his Mom half-naked and apparently without any good food in the house. Police had interviewed her before they medically got Horace checked at the hospital as further endorsed by a Justice of the Police who had examined evidence that the Plaintiff had presented her Honour.

REPLY 10.

A medical examination of Horace Carby-Samuels was initiated based upon due diligence by both the Justice of the Peace and the Ottawa Police who contacted neighbours to establish whether there was grounds for a medical examination, and was also made in conjunction with consultation with officers of the Ontario government. There was no such swearing that Horace Carby-Samuels was “insane” as alleged by the Defendants.

MARCELLA'S [and her father's] DEFENCE 11:

The Defendants state that they have not prevented the Plaintiff from seeing his severely incapacitated mother and visitation encounters with his mother could be arranged, however, only under terms of adequate safety and supervision, having regard to his efforts / threats to capture or kidnap her.

EDITORIAL NOTE: We, at The Canadian, have obtained, a copy of yet another Legal Demand Letter issue by the Plaintiff's lawyer before Christmas that Marcella along with her father did not respond to. This is another apparent lie orchestrated by Marcella who has prevented Raymond from seeing his own Mother against the wishes of both him and his Mother. Marcella has simply wanted the Plaintiff “out of the way” and not caring for his Mother who he sought to take care of and who had been successfully helping with her recovery.

REPLY 11.

The Defendants alleged that they have not prevented the Plaintiff from seeing his Mother while at the same time complaining to police that attempts made by the Plaintiff to see his Mom constitute “harassment” while getting the Centre that had began to initiate meetings to stop doing so by getting Robert Griffin Jr, to interfere in the work of the Nepean, Rideau and Osgoode Resource Centre was doing in behalf of thew Plaintiff and his Mom.

Mr Griffin is an apparent “rogue” cop that the Defendants privately recruited to engage in illicit activities against the rights of the Plaintiff. This rogue cop physically threatened the Plaintiff on more than one occasion and also illegally demanded that the Plaintiff stop contacting relatives upon the the direction of Marcella Carby-Samuels and not the Plaintiff’s relatives he had admitted.

The Ottawa Police had delegated the Nepean, Rideau and Osgoode Resource Centre to enable contact between the Plaintiff and his Mom, and the Defendants then used the rogue cop services of Dr. Griffin to unravel the coordination secured by the Ottawa Police to obtain the services of this Centre.

Furthermore, the Defendants ignored a Legal Demand Letter in July 2015 sent to encourage the Defendants to facilitate access between the Plaintiff and his Mom [Appendix 2 ] *; and that letter was ignored just like the most recent letter written by the Plaintiff to the Defendants' Legal Representative dated 16 December 2015 [Appendix 3] *.

• Please note that Appendices are in the Original documents filed with the Court against Marcella and her father's actions.

MARCELLA'S [and her father's] DEFENCE 12:

The defendants also plead it is the Plaintiff who is actually harassing and malicious with his intent to destroy his sister and her professional career.

REPLY 12.

Marcella Carby-Samuels lied to the Police in the initial report that she made on 8 January 2015 (15-5493) against the Plaintiff, and in subsequent reports and has spearheaded an apparent campaign the criminalize the Plaintiff that would lead to the eviction of the Plaintiff from his home.

Apparently, the legal efforts of the Plaintiff to clear his name from the lies of the Defendants are “destroying his sister and her professional career”.

Marcella is a sister of the Plaintiff in name only. In practice, Marcella is a liar who has sought to criminalize the Plaintiff and destroy her own Mother without empathy or integrity.

MARCELLA'S [and her father's] DEFENCE 13:

Additionally, the Defendant Horace Carby-Samuels states the Plaintiff is fabricating reports about his sister's lobbying to get his out of his parent's will.

EDITORIAL NOTE: While she could still talk, when the Plaintiff was still being the active care giver, the Plaintiff's Mom while shaking, informed the Plaintiff of the activities that the Defendants had been planning and informed him that Marcella was also “sucking up” to her father in order to manipulate him. The Plaintiff's Mom said that she told her husband that Raymond is her only son which was apparently a comment ignored by the Defendants who had shown no integrity toward the Plaintiff and his Mother.

REPLY 13.

It is the Defendants who fabricate and machinate against the Plaintiff.

MARCELLA'S [and her father's] DEFENCE 14:

The Defendant Horace Carby-Samuels states the Plaintiff's claim about contributing to the operation of the household up to over $1,000.00 per is essentially not true and again a fallacy.

EDITIORIAL NOTE: Raymond has also spent thousands of dollars associated with court costs in trying to see his Mom who he as not seen since 12 June 2015 thanks to the illicit and illegal activities of the Defendants and their hired helper Robert Griffin. If you are as outraged by the activities of Marcella who has been working both for Lund University and the United Nations while blocking the Plaintiff and his Mom seeing each other into Christmas Day. You can make a donation via PayPal by contacting us via Agorapublishing.com and we would then forward these donations to the Legal Defence of the Plaintiff.

REPLY 14.

The Plaintiff would not be able to afford to rent and furnish his current place and buy food among other expenses incurred as a result of the Defendants demonstrated lack of empathy to the Plaintiff if he was not in a financial position to contribute over $1,000 per month to expenses at 30 Jarlan Terrace.

If we believe the Defendant's story that this was not possible, the Plaintiff should have been living on the streets after he was evicted because “after all” according to the Defendants, the Plaintiff was a “freeloader” without the money to support household expenses that he had provided.

MARCELLA'S DEFENCE 15:

Robert Griffin [is] a detective in the elder abuse unit of the Ottawa City Police who was assigned to see that the Plaintiff desisted in his continuing harassment of the Defendants; he was also assigned to assist our accommodation to the new living arrangements ad the Plaintiff's assertion about the function of Mr. Griffin as a personal agent also demonstrates another fallacy.

REPLY 15

Robert Griffin pursued apparent illicit activities against the Plaintiff in behalf of the Defendants. He would show-up outside of his normal working hours and never once showed his police badge and appeared to be working in behalf of the Defendants in a clandestine arrangement consistent with a “rogue” or “dirty cop”.

MARCELLA'S [and her father's] DEFENCE 16:

The Defendant states that the allegation made to the effect that Horace Carby-Samuels attacked and assaulted the Plaintiff causing bodily harm in another fabrication to this narrative concocted in the Plaintiff's mind as the Plaintiff injured himself by acting stupidly but subsequent to that event, and his report of the event to the police, he formulated the imputation of an attack by Horace Carby-Samuels.

EDITORIAL NOTE: One evening the Plaintiff was standing beside the refrigerator in the kitchen when he began to express concern about the continuing neglect of the Plaintiff's Mother. The Plaintiff tells us at The Canadian that within seconds, Horace developed a wild eyed angry stare, began shouting and charged Plaintiff who was standing beside the refrigerator. He then too out a sharp knife out of the kitchen draw beside the refrigerator and pointed it toward the defendants stomach within less than a centimetre.

The Plaintiff immediately grabbed the knife with his left hand to prevent from being stabbed in the stomach by the Plaintiff resulting in an almost severed “pinkie” finger and critical nerve that required emergency reconstructive surgery and about six months of physical rehabilitation. The initial police report did not contain the full details of the incident in order to spare the Marcella's father from a possible jail sentence, and also since the Plaintiff was living at 30 Jarlan Terrace; but this report was later amended when the Plaintiff lived at his current address, and was safely away from Marcella's and Horace's violence.

Horace took a violence against Marcella's violence against the Plaintiff by offering to do favours that including buying new fixtures in bathrooms at 30 Jarlan Terrace in exchange for Marcella getting her father's loyalty ignoring all physical and psychological violence perpetrated against the Plaintiff.

Marcella would ignore the violence that her father perpetrated against the Plaintiff's Mom and Horace would ignore the violence he also sought to perpetrate against the Plaintiff in an alleged criminal conspiracy.

REPLY 16.

Horace Carby-Samuels inflicted bodily assault against the Plaintiff that is consistent with the Plaintiff's Mom handwritten note of abuse and is consistent with reports that persons with Type 2 Diabetes can have violent tendencies as a result of their diabetic state.

If Horace was not the perpetrator of an attack against the Plaintiff, then why did Horace not make the call to 911 having alleged that the Plaintiff cut himself? It was the Plaintiff who made the call to 911.

Horace did not call 911 because he was the attacker. Ottawa Police officers would accept the amended Police Report filed by the Plaintiff against Horace Carby-Samuels because the Plaintiff's representation of the facts was consistent with the forensic evidence. The wound experienced by The Plaintiff could not have been self-inflicted.

MARCELLA'S [and her father's] DEFENCE 17:

At no time did the Defendant Horace Carby-Samuels prevent Raymond from carting away his personal effects. When, with the supervision and assistance of The Ottawa Police, he was given the opportunity to recover his personal effects and belongings, he cherry picked the material, and left the bulk of his belongings on the premises at 30 Jarlan Terrace. However the material was moved to U Haul storage, (and then transferred to him) thereby by giving him the opportunity to use his non removal of the material, as legal leverage to regain entry to the premises.

EDITORIAL NOTE: The Defendants apparently mean that they did not want the Plaintiff to be able to see his Mom, and feared that the property that they were denying access to the Plaintiff could be used as a legal means for the Plaintiff being able to see his Mom onsite who was began to get less and less mobile thanks to the activities of the Defendants. It is apparent that the eviction perpetrated by the Defendants was illegal – and made with the support of Marcella's operative Robert Griffin – because such an eviction would have required the consent of both Horace Carby-Samuels and the Plaintiff's Mom's endorsement as a co-owner of 30 Jarlan Terrace.

In the illegal eviction perpetrated by the Defendants, Marcella used her operative Robert Griffin to deny her request to at least see her son on weekends.

REPLY 17.

Horace Carby-Samuels only released the majority of the Plaintiff's belongings after a Demand Letter from the Plaintiff's Lawyer, and the reason he elected to do this is because Horace had stopped allowing the Plaintiff on Jarlan Terrance and declared to the Ottawa Police that 30 Jarlan Terrace would be “off limits” to the Plaintiff. The idea that the Plaintiff voluntarily “cherry picked” his belongings and left them at 30 Jarlan Terrance is another lie.

Furthermore, Horace did not give the entire personal belongings back to the Plaintiff which is a part of the Plaintiff’s Statement of Claim.

MARCELLA'S [and her father's] DEFENCE 18:

The Defendants state that the appendix purporting to be a set of written statements by the Plaintiff's mother is in hall likelihood a forgery, in light of the mother's writing incapacity.

REPLY 18.

The allegation by the Defendants that attached notes associated with the Plaintiff's Statement of Claim are forgeries are slanderous.

At the time when the Horace with the backing of Marcella evicted the Plaintiff, Dezrin could still walk and write under the care of the Plaintiff that Marcella sought to remove from 30 Jarlan Terrace to apparently expedite the a decline in health of the Plaintiff's Mom while also seeking to eliminate the Plaintiff's Mom as a witness to the lies of the Defendants.

MARCELLA'S [and her father's] DEFENCE 19:

The Defendants hereby ask the court to review the Plaintiff's claim and dismiss said claim as it does not disclose a reasonable cause of action.

REPLY 19.

The Defendants' opposition to the said Claim is based upon verifiable lies and slander and appears to lack any supporting affidavit submitted within the time required to file a defence. Therefore, the Defendants have not presented a bona fide statement of Defence. The Plaintiff asks that the Statement of Defence be declared as invalid by the Court and for the Court to proceed with Summary Judgement against the Defendants who have sought to mislead the Court.

OVERALL:

The Defendants who in their Statement of Defence, admit to the severe physical incapacity of the Plaintiff's Mom who they continue to deny the ability to see her own son – contrary to their laughable pretence of doing otherwise – betray their total lack of morality, and specifically their lack of human decency they have demonstrated and continue to perpetrate against the Plaintiff and his Mom.

[Original Signed by the Plaintiff]

Has Marcella skillfully manipulated her father who is a co-defendant in an apparent agenda to condemn the Plaintiff's Mom to a “slow death”. Has Marcella committed a terribly atrocity against the Plaintiff and his Mother?

You be the judge.