Chapter 9 – Read the new website at; www.kingsoutdoorcanada.com or left click & scroll down to read; Evidence The Alberta Justice Department conspired with The Plaintiff’s lawyer Elizabeth MacInnis – Moore daughter of Alberta Chief Justice W. Kenneth Moore to orchestrate the outcome of Queen’s Bench action 9703-12949 and wrongfully convict and imprison an innocent senior, Donald H. Broder.

BRODERBUCK

Presents

THE BUCK FOR JUSTICE

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Alberta Court of Queen’s Bench action # 9703-12949 whereby;

Donald H. Broder was the Defendant;

This page will provide evidence to you the reader that;

1. The application for probate to appoint Personal Representatives had not been before the Surrogate Courts and as such were not named as Plaintiff’s on the Statement of Claim or The Amended Statement of Claim prior to the Plaintiff’s lawyer obtaining a Court Order that closed the pleading within the said action on March 15, 2001.

2. The Issue of Standing that was raised within paragraph 8 of The Original Statement of Defence was concealed from the trial Judge Justice Myra Bielby by Donald Broder’s own lawyer Bryan Kickham of Miller Thomson by his willful actions of amending the Statement of Defence on January 9, 2004 just 10 days before the scheduled trial of January 19 – 23, 2004 then he back dated the FIAT “permission to amend” to January 9, 2003 knowingly that The Amended Statement of Defence would become  total precedence and the trial Judge would not be privy to see that the issue of standing / lack of personal Representatives had been raised in The Original Statement of Defence.

3. Elizabeth MacInnis of Weir Bowen was in Contempt of Court for not following the Order of Chief Justice A. H. Wachowich to file the Certificate of Readiness on or before March 15, 2001 immediately following the Defendants outstanding 129 Application..

4. The 129 Application refereed to in the Order of Chief Justice A. H. Wachowich was heard by Master Quinn in the Edmonton Law Courts and was to preclude the filing of the Certificate of Readiness.

5. In November of 2001- Justice C. P. Clarke acted biased and prejudice by Ordering the substitution of the Personal Representatives within action 9703-12949 filed date of July 8, 1997 during Donald Broder’s Appeal of Master Quinn’s decision circumventing the Statutes of Limitation Act of the two year deadline to add or substitute a new Plaintiff.

6. The Case Management Meeting minutes will provided evidence Elizabeth MacInnis of Weir Bowen was in Contempt of Court for not complying with the Order of Chief Justice A. H. Wachowich by her willful actions  delaying the filing of the Certificate of Readiness from March 15, 2001, and committed fraud on the Courts by misleading Justice Marceau the conditional Certificate of Readiness was filed on April 17, 2003.

7. The False Contempt of Court hearing on April 23, and July 13, 2004  whereby Elizabeth Macinnis of Weir Bowen had Donald Broder incarcerated for not following a 2004 Court Order , when as the evidence will prove it was Elizabeth MacInnis that did not follow the 2001 Court Order of Chief Justice A. H. Wachowich to file the Certificate of Readiness on or before March 15, 2001.

8. Cross-Examination of Guy Lacourciere will provide evidence that; Quote: “a comment was made, first of all, by Elizabeth MacInnis, that she had been ambushed.”

Note:

If Elizabeth MacInnis commented she had been ambushed by Robert Sawers then it should raise the question, how did she win the Litigation?

I, Donald H. Broder will provide to you the reader evidence of Conspiracy to Defraud an innocent senior citizen by all the named participants for whom conspired and colluded and ambush me because Justices from the Edmonton Law Courts were upset because my own lawyer Robert J. Sawers had ambushed Elizabeth MacInnis of Weir Bowen and her daddy was the Chief Justice W. Kenneth Moore for whom Chief Justice A. H. Wachowich had just replaced.

References included on this tab;

Alberta Rules of Court; Are Regulations

Alberta Rules of Court; Rule 133 : Required to be followed to amend any defect or error on the Statement of Claim

Alberta New Limitation Act adopted March 1, 1999; Statute

Case Law;

Rocklake vs. Timberjack ; Quote: Regulations cannot override statutes.

Did you know!

The Statute of Limitations Act and Rocklake vs. Timberjack case law support that the addition of new plaintiffs are not allowed after the 2 year limitation period has lapsed.

In November, 2001 Justice C. P. Clarke ordered the substitution of the Personal Representatives as Plaintiffs within Action 9703-12949 excess of 4 years had lapsed since the Statement of Claim was filed at Edmonton Law Courts July 8, 1997.

By the time Action 9703-12949 was initiated; Donald Broder had the Mule Deer Trophy in his exclusive possession for excess of 23 years, 1973 – 1997.

Alberta Court of Queen’s Bench  action 9703-12949 was commenced on July 8, 1997 and;

The substitution of new plaintiffs ” The Personal Representatives” did not occur until November of 2001,  “excess of 4 years”

after Elizabeth MacInnis of Weir Bowen had obtained and Order to close the pleadings within the said action on or before March 15, 2001.

Statement of Claim ( full version) PDF

Filed July 8, 1997 at The Edmonton Law Courts, by Grace Parrotta-King of Hunt,Young, Parrotta-King

• The Personal Representatives are not named as Plaintiffs on the Statement of Claim.
• The Plaintiffs and the Defendant Don Broder are all siblings while the Defendant Craig Broder is the son of the Defendant Don Broder.

Statement of Defence(full version)PDF

Filed July 28, 1997 at the Edmonton Law Courts, by Joseph J. Kueber of Bryan & Company

• The Defendants raised the issue of standing as per Alberta Rules of Court Rule 129 within paragraph 8 of the original Statement of Defence.

Paragraph [8] quote:

“The Defendants claim that the claim against them by the Plaintiffs is frivolous, vexatious and otherwise an abuse of process and claim costs on a solicitor and his own client full indemnity basis.“

We will provide evidence that on January 9, 2004 just ten days before the scheduled trial of January 19 – 23, 2004 the Statement of Defence was amended by Bryan Kickham of Miller Thomson whom was retained to act on behalf of the Defendant, Donald Broder for whom willfully conspired against his own client to conceal from the trial Judges as to the first time the issue of standing was raised by amending the Statement of Defence the trial Judge would not see the Original Statement of Defence.

Procedure Record Print “full set” (full version)PDF (bottom of the first page shows Grace Parrotta-King file date of Cease to Act and first line of the second page)
On June 1, 1998 Elizabeth MacInnis of Weir Bowen replaced Grace Parrotta-King as Solicitor for the Plaintiffs.

Justice Lewis Order(full version)PDF
Heard on December 18, 2000

It was ordered;

• [1] The Plaintiffs have leave to file an Amended Statement of Claim in the form attached hereto. Whatever limitation defences were available to the Defendants at the date of the amendments are preserved.
• [5] The Certificate of Readiness to set this action for trial shall be filed on or before February 15^th, 2001. If the Defendants fail to agree to the filing of a Certificate of Readiness, the Plaintiffs counsel shall submit the Certificate of Readiness signed by them, and it shall be accepted by the Trial Coordinator in that form, and trial dates shall be assigned.

Amended Statement of Claim (full version)PDF

As per Justice Lewis the Amended Statement of Claim was Filed March 12, 2001 at the Edmonton Law Courts by Elizabeth MacInnis of Weir Bowen;  3 days before the March 15, 2001 deadline as set out by Chief Justice A. H. Wachowich Order to file the Certificate of Readiness.

Did you know!

• The Personal Representatives were not appointed at the Surrogate Court until May 24, 2001 when Elizabeth MacInis of Weir Bowen obtained an Order to close the Pleadings on or before March 15, 2001.
  
• The Application for Grant of Administration was not even initiated by Elizabeth MacInnis of Weir Bowen when she obtained an Order to close the Pleadings.
• The Amended Statement of Claim was filed in the form attached as per the Justice Lewis Order and proves the Application for Probate to appoint Personal Representatives was not considered by Elizabeth MacInnis of Weir Bowen at the time she had forced the Pleading closed by way of a Court Order.
• The Personal Representatives were not named as Plaintiffs on the Amended Statement of Claim as filed per the Justice J. L. Lewis Order.

The Certificate of Readiness was to be filed on or before February 15, 2001 to close the Pleading as per the Justice Lewis Order and then an extension of time to file the Certificate of Readiness to March 15, 2001 granted to the Defendant’s; Donald H. Broder and Craig Broder by Chief Justice A. H. Wachowich.

Did you know:

Donald Broder and Craig Broder had won the Alberta Court of Queen’s Bench action 9703-12949 on March 15, 2001 and all pages that follow will provide the evidence of corruption within Alberta Justice and lawyers to orchestrate the outcome in favor of Elizabeth MacInnis of Weir Bowen because she had complained she had been ambushed to her daddy past Chief Justice W. Kenneth Moore.

Edmund Broder’s deceased December 26, 1968 in excess of 30 years to this date and still no; Application for Probate.

The Limitation of Action Act adopted in March 1, 1999 has become Legislation and Elizabeth MacInnis is not allowed to add a new Plaintiff to action 9703-12949 as excess of 2 years have passed since the commencement of this action on July 8, 1997 and the filing of the Certificate of Readiness on March 15, 2001.

Alberta’s New Limitation Act(full version)PDF
“2 year limitation period and the 10 year drop dead clause”

Only two limitation periods: the earlier of

• two years from the time the claimant knew or ought to have known of the claim, or
  ten years from the time the claim arose

b. adding claims and new claimants

Where an added claim adds or substitutes a claimant:

• the defendant must have received, within the limitation period applicable to the added claim (plus the time provided for service), sufficient knowledge of the added claim that the defendant will not be prejudiced in maintaining a defence to it on the merits;

Rocklake vs. Timberjack (full version)PDF

• (4]”That notice of motion does not seek any change to the body of the statement of claim, merely “adding or substituting Lee St. Jean as a Plaintiff in this action”.
• (15] The problem in the present case is not that the Rules of Court lack powers to amend parties or pleadings. They have them. No modern decision on amendment suggests that there is any difficulty curing parties before the limitation expires. The problem is that there was an independent statute, the Limitation of Actions Act, which restricted times to sue.
• (18] The analytical approach adopted in Alberta is simple. One cannot sue after the limitation period. Adding a new plaintiff or a new defendant or a new cause of action to a suit after the period expires, in effect creates a new suit, so far as that new party or cause of action is concerned. Limitations legislation is intended to give repose after a certain length of time, new plaintiff or new cause-of action violates that policy almost as much as adding a, new defendant.
• (19] The Rules of Court do not speak about limitation periods or times to amend. They have always been reconciled with limitations legislation by presuming that the powers under the Rules are to be exercised subject to the time limits under the legislation, when those are relevant; cf. Nagy v. Phillips (#1) (1996) 187 A.R. 97,41 Alta. L.R. (3d) 58,64 (C.A.); Leesona v. COllSOI. TextiLe Mills [1978] 2 S,CR. 2,8-9, 18 N,R. 29. Furthermore, the Rules of Court are a Regulation, and were not confirmed by statute until the 1970s. Regulations cannot override statutes.

Chief Justice A. H. Wachowich Order (full version)PDF

Justice A. H.Wachowich became aware that Robert Sawers had timed the 129 Application for the Defendants and that a Jury would not be required if there was to be no trial with the Defendants likely success having the claim dismissed as it was frivolous, vexatious, and otherwise an abuse of process as per Alberta Rules of Court Rule 129, as the Plaintiffs in their personal capacity lacked standing to sue and Alberta New Limitation Act would not permit the Courts to add or substitute a new plaintiff after the two years limitation period had expired as defined within the relevant case law; Rocklake vs. Timberjack, Alberta Court of Appeal.

W. J. Quinn Order (full version)PDF

• [4] If no one is appointed as Administrator it is my intention to strike out the Statement of Claim.

Cross-Examination of Guy Lacourciere

Mr. Broder questioning Guy Lacourciere;

Page 28 Lines 12 – 27 and Page 29 Lines 1 – 18

• Q: What do you mean by “ambushed Ms. MacInnis?”
• A: The Court had asked the question
• Q: If we ambushed Elizabeth MacInnis
• A: It appears to us that Ms. MacInnis may have been ambushed by the motion, by Sawers, in respect to – in respect to the motion that had been filed in 2001. And at that point in time what I had told the court of appeal is that the matter had originally been set out in the statement of defence.
• Q: I need some clarification that we ambushed Elizabeth Maclnnis.
• MR. WONG: That’s what the court of appeal said.
• Q: MR. BRODER: We ambushed her? Is that not when you raised issues, is that not considered a lawyer of competence to know when and wait until the issue being raised might be to your advantage — or to our advantage?
• MR. WONG: Do you understand that?
• A: THE WITNESS: No.
• MR. WONG: No. Can you repeat?
• Q: MR. BRODER: All I’m saying, if you’re going to wait to file motion 129, would it not be to our advantage if our solicitor waited for a timely application?
• A: Let’s be clear. You filed a statement of defence. In the statement of defence it raised the issue of standing, okay? Later on a comment was made, first of all, by Ms. MacInnes, that she had been ambushed. At which point in time the court asked me about being ambushed. And I said to the court, I said, no, that the — that Ms. Maclnnes was not ambushed, that the matter has been raised originally in the statement of defence that had been filed by Mr. Sawyer.

Note: If Elizabeth MacInnis of Weir Bowen had complained she had been ambushed by Donald Broder and Craig Broders Lawyer Robert Sawers in March of 2001 the rest of the website will provide the evidence that will prove beyond a reasonable doubt how The Alberta Justice Department, Justices and Lawyers came to Elizabeth MacInnis cry and willfully participated in a conspiracy to ambush Donald Broder and Craig Broder by completely orchestrating all the events within Action 9703-12949 that follow.

Elizabeth MacInnis of Weir Bowen ignores the Chief Justice A. H. Wachowich Order and proceeded to make an Application for Probate without effective service of the Notice to Beneficiaries and Application for Probate on Donald Broder (see Surrogate Court tab).

As soon as Elizabeth MacInnis of Weir Bowen filed the Certificate of Readiness as per the Chief Justice A. H. Wachowich’s Order, she would not be able to represent the Estate of Edmund Broder as she would be in a conflict position being against Donald Broder in action 9703-12949, and now to represent him as one of the Beneficiaries in the pending Estate Litigation.

As per the Orders of Justice J. L. Lewis and Chief Justice A. H. Wachowich, Elizabeth MacInnis had just closed the pleadings on herself, and Donald Broder’s “Alberta Rules of Court Rule 129 Application” before Master Quinn was successful that the claim was frivolous, vexatious and abuse of court process, lacked standing as no Administrators had been Granted at the Surrogate Courts, as the application for Probate had not been filed for excess of 30 years, and as such the Personal Representatives did not exist and obviously could not be substituted as Plaintiffs within this action as the two year limitation period to add or substitute a party had expired.

Elizabeth MacInnis ignored the Order of Chief Justice A. H. Wachowich and colluded with Guy Lacourciere to orchestrate another round of case management meeting, playing case management Justice Marceau to lead him on that the Conditional Certificate of Readiness had been filed on April 17, 2003 instead of March 15, 2001, as per the Wachowich order.

This delay prevented Elizabeth MacInnis from acting in conflict, if she had filed the Certificate of Readiness on March 15, 2001, she could not act on behalf of the Estate of Edmund Broder, as she was counsel within action 9703-12949 as of against Donald Broder a beneficiary, and could not now represent him.

The Surrogate Court Tab will provide evidence that Elizabeth MacInnis refused to file Master Quinn’s Order, which would purposely delay the filing of the Certificate of Readiness, until such time that the Application for Probate had been made within the Surrogate Courts appointing two of the Plaintiffs as Administrators and relying on a misleading Affidavit of Service for the Surrogate Court Application so that I, Donald Broder would not be served and unaware the Application for Probate had been scheduled on May 24, 2001. Elizabeth MacInnis was successful in obtaining the Grant of Administration on May 24, 2001 excess of two months after the Court Order deadline of March 15, 2001 that she obtained which force the pleadings closed within action 9703-12949.

The Orchestrated Trial Tab will provide evidence how the Alberta Justice Department colluded with Elizabeth MacInnis to have the Personal Representatives added as Plaintiffs to the Amended Statement of Claim. It will prove that when I, Donald Broder appealed Master Quinns Order before Justice C. P. Clarke, why he winked at my Solicitor and said add them, as Elizabeth MacInnis was not allowed to extend the time for filing the Certificate of Readiness as per Chief Justice A. H. Wachowich’s Order, and as such would not be able to file an Application as per Rule 133 Alberta Rules of Court to request the Courts allow the addition of the Personal Representatives as Plaintiffs. Justice J. P. Clarke acted in collusion to orchestrated the substitution of the Personal Representatatives as Plaintiffs to prevent Elizabeth MacInnis from being ambushed.

Elizabeth MacInnis also had to obtain cooperation from another one of my Lawyers, Bryan Kickham to conceal the first time the issue of standing was raised, so Bill Kenny of Miller Thomson called and suggested that I speak with Bryan Kickham of Miller Thomson to act on my behalf for the upcoming trial, I met with Bryan Kickham and paid his retainer, only to be framed again, as Bryan Kickham filed an Amended Statement of Defence 10 days before the trial, unbeknown to me that it would become “total precedence” for the sole purpose to conceal from the trial Judge that the first time the issue of standing was raised was within my Original Statement of Defence, for which the trial Judge would only be allowed to see the Amended Statement of Defence.

I will also prove that Elizabeth MacInnis of Weir Bowen had me incarcerated for not following a Court Order, when as the evidence will prove before you, it was Elizabeth MacInnis that did not follow the Chief Justice A. H. Wachowich Order, and colluded with the Justice Department to frame me.

Case Management Meeting Minutes (full version) PDF
Case Management Meeting Minutes May 7^th, 2003 – Case Management Judge: The Honourable Mr. Justice R. P. Marceau

Appearances

• Counsel for the Plaintiffs – Elizabeth M. MacInnis
• Counsel for the Defendants – Guy Lacourciere

Steps in Litigation

• Ms. MacInnis confirmed that the Conditional Certificate of Readiness had been filed with the Courts on April 17, 2003.
• Guy Lacourciere acting for Donald Broder did not inform Justice Marceau of the Chief Justice A. H. Wachowich order to file the Certificate of Readiness on or before March 15, 2001..
• Elizabeth MacInnis of Weir Bowen concealed from Justice R. P. Marceau the deadline to file the Certificate of Readiness as per the Chief Justice A. H. Wachowich Order.
• Elizabeth MacInnis was in Contempt of Court, committed Fraud on the Courts, and in breach of the Legal Profession Act.

For the record; I, Donald H. Broder bring to the attention of the Canadian citizens what;

Elizabeth MacInnis told the trial Judge, Madame Justice Myra Bielby;

That Donald Broder should be imprisoned for not following a Court Order.

• When the evidence has proven it was Elizabeth MacInnis that did not follow a previous Court Order of the Chief Justice A. H. Wachowich.
• Had Elizabeth MacInnis followed the Wachowich Order to file the Certificate of Readiness and close the pleadings on March 15, 2001, I, Donald Broder would not have been subject to the Court Order issued in March 2004 by the Trial Judge, Justice Bielby as there would not have been a trial, action 9703-12949 should have been struck as per the Master Quinn Order.

Official Transcripts of Donald Broder’s false contempt charge April 23, 2004(full version)PDF
April 23, 2004 1:09 pm session

E. MacInnis, Ms. For the Plaintiffs to Justice Bielby

[page 1 line 18-19]

“We are making application to have Mr. Broder held in civil contempt of both Your Ladyship’s judgement…”

[page 3 line 25-27 / page 4 line1-14]

“And at this point, I guess we’re asking the Court to enforce the order that it’s given. And although I’m somewhat reluctant to ask for this remedy, I really do not see any other effective remedy other than to request that the defendant be imprisoned for his contempt of the Court’s order. It’s — clearly, he’s been ordered to give this. He hasn’t done so. I don’t know of any other effective way to get Mr. Broder to comply with the order of Court. And what I would be asking for would be, you know, a short period perhaps of imprisonment, after which he could perhaps be brought before the Court to have an opportunity to purge his contempt, you know, two or three days, something of that sort. And it’s my submission that’s the only way that the Court order, you know, can be effected, unless my friend has some other suggestion at this point.”

Official Transcripts of Donald Broder’s false contempt charge July 13, 2004(full version)PDF
Edmonton, Alberta July 13, 2004

E. MacInnis, Ms. For the Plaintiffs speaking to Justice Myra Bielby.

[page 8 line 2-9]

“My point regarding that, My Lady, is that there has been a — there was a previous finding of contempt against Mr. Don Broder in these proceedings, and it’s my submission that is a relevant factor to look at. He had previously been found in contempt of Court in the same action, and that was by Justice Marceau last November. So, it’s not the first time that Mr. Don Broder failed to comply with a Court order.”

[page 8 line 20-21]

“He chose instead to say nothing to go to — to be imprisoned.”

[page 8 line 22-26]

“There has been another factor, I think, that the Court looks at as to whether the defendant, or person who’s in contempt, has made an apology to the Court. Well, there has been no apology made here by Mr. Don Broder.”

[page 9 line 14-17]

“And it’s my submission that the Court should send a strong message to Mr. Don Broder that when a Court order is given, that it ought to be obeyed. What are we seeking is a penalty, which I this is a — would be.”

Elizabeth MacInnis was in Contempt of Court on March 15, 2001, the Contempt issues she speaks about as of against me, Donald Broder were in 2003, and 2004.

Cross – Examination of Guy Lacourciere (partial version)PDF

Mr. Broder questioning Guy Lacourciere;

Page 28 Lines 12 – 27 and Page 29 Lines 1 – 18

• Q: What do you mean by “ambushed Ms. MacInnis?”
• A: The Court had asked the question
• Q: If we ambushed Elizabeth MacInnis
• A: It appears to us that Ms. MacInnis may have been ambushed by the motion, by Sawers, in respect to – in respect to the motion that had been filed in 2001. And at that point in time what I had told the court of appeal is that the matter had originally been set out in the statement of defence.
• Q: I need some clarification that we ambushed Elizabeth Maclnnis.
• MR. WONG: That’s what the court of appeal said.
• Q: MR. BRODER: We ambushed her? Is that not when you raised issues, is that not considered a lawyer of competence to know when and wait until the issue being raised might be to your advantage — or to our advantage?
• MR. WONG: Do you understand that?
• A: THE WITNESS: No.
• MR. WONG: No. Can you repeat?
• Q: MR. BRODER: All I’m saying, if you’re going to wait to file motion 129, would it not be to our advantage if our solicitor waited for a timely application?
• A: Let’s be clear. You filed a statement of defence. In the statement of defence it raised the issue of standing, okay? Later on a comment was made, first of all, by Ms. MacInnis, that she had been ambushed. At which point in time the court asked me about being ambushed. And I said to the court, I said, no, that the — that Ms. Maclnnis was not ambushed, that the matter has been raised originally in the statement of defence that had been filed by Mr. Sawyer.

The response of The Attorney General – Alison Redford (full version)PDF

The evidence provided within the Orchestrated Trial, Surrogate Courts, Appeal Courts and the Supreme Court of Canada tabs will provide evidence that;

Alison Redford – Attorney General – Justice Minister and The Department of Justice participated in ambushing an innocent senior citizen because;

Guy Lacourcieres cross-examination: Quote: a comment was made, first of all, by Elizabeth MacInnis, that she had been ambushed!

Robert Sawers had let Elizabeth MacInnis of Weir Bowen force the Pleadings closed on herself by way of a Court Order from Justice J. L. Lewis and Chief Justice A. H. Wachowich, without informing her she requires Personal Representatives appointed at the Surrogate Courts to legitimize the Statement of Claim!

The Justices of the Edmonton Law Courts were disgruntled that Robert J. Sawers – for whom represented Donald Broder had ambushed Elizabeth MacInnis and all Lawyers and Justices named willfully conspired to frame an innocent citizen for the sole purpose to defraud him financially, dehumanize him, and teach him a lesson because his own lawyer was accused of  ambushing a Lawyer, for which Donald H. Broder was not even aware the meaning of the events that had happened.

Elizabeth MacInnis of Weir Bowen could not act for the Beneficiaries of the Estate as she was now in a conflict position and only looking out for her own best interest by;

Refusing to file the Order of Master Quinn to purposely delay the filing of the Certificate of Readiness, so she could buy time to apply for Probate before the Pleadings closed.

The Surrogate Court Tab : provides evidence of the misleading Affidavit of Service sworn by the legal secretary of Elizabeth MacInnis, Joan C. Hill for the Surrogate Court Application heard on May 24, 2001 excess of 2 months after the pleadings were closed within action 9703-12949.

The Orchestrated Trial Tab : provides evidence Justice C. P. Clarke added the Personal Representatives to the Amended Statement of Claim without following the Alberta Rules of Court with a Court Application and outside the applicable 2 year Limitation Period, as per case law Rocklake vs. Timberjack. Iit will also provide evidence that Bryan Kickham lawyer for Donald Broder Amended The Statement of Defence 10 days before the trial, backdated the FIAT “authority to amend” from January 9 2004, to January 9, 2003 ” and someone forged the Judges second signature, for the sole purpose to conceal from the Trial judge as to the first time the issue of standing was raised was within the Original Statement of Defence, knowingly the Amended Statement of Defence would become total precedence at the trial, and the trial Judge would not be allowed to see the Original Statement of Defence so that estoppel would not prevent Elizabeth MacInnis from relying on the relation back doctrine to win the lawsuit.

The Appeal Court Tab: provides evidence Justice Carole Conrad, Ronald Berger and Peter Costigan were made aware in the Appeal Books the first time the issue of standing was raised was within the original Statement of Defence on July 28, 1997 and not as Elizabeth MacInnis had told the trial Judge early 2001, also that Bryan Kickham of Miller Thomson had amended the Statement of Defence purposely to conceal the first time the issue of standing had been raised from the trial Judge Justice Bielby.

Why: [82] Estoppel had been plead and would prevent Elizabeth MacInnis from relying on the relation back doctrine to win the lawsuit!

The Supreme Court of Canada Tab: The Supreme Court had been shown within the Application for Leave the Original Statement of Defence , [82] of the Reasons for Judgment of Justice Myra Bielby, but not shown that Elizabeth MacInnis has mislead the trial Judge during the arguments as to the first time the issue of standing / lack of Personal Representatives had been raised, Chief Justice Wachowich Order, misleading Affidavit of Service for the Application for Probate, and that Justice C. P. Clarke had substituted the Personal Representatives without an Application as per Alberta Rules of Court and Alberta’s New Limitation Act.

The Outstanding Issues Tab: Health Care fraud by garnishing a terminally ill senior of her much needed money for medical care to pay for court cost for suing the Lawyer involved for which she had nothing to do with.