Freedom of Expression: My claim for damages

I told you how I filed what I'm calling "The Mother of All Lawsuits" and the University has responded with a Motion to Strike. Interestingly enough, they're pretty serious about moving forward with this; we appeared before the Master on Monday, and Ms. Mulholland said she would have their brief in by next Tuesday. So the ball is in motion.

I told you how it's a very long and complex claim, with separate sections dealing with defamation, breach of duty of care, and other things. Probably the most interesting portion of the claim is the very last section, which I added in after giving the matter a great deal of consideration. I'm suing them under the Charter of Rights for violating my right to freedom of expression.

How do I expect to get away with this? Everyone knows that in University, you tell the profs what they want to hear, and if you don't they give you a low mark. They shouldn't but they often do. So what? How are you going to prove that? The prof will just say that the mark was based on the quality of the work, not the opinions expressed. And the courts are not going to second-guess them on that.

Unless you can put together such an overwhelming case to prove that it had to be your opinions that they were punishing you for. But how are you ever going to get enough evidence for that?

I think I just might have enough. Here is the portion of my Statement of Claim which lays out how the U of W violated my right to Freedom of Expression. I think it's worth a read-through.

The Plaintiff’s claims with regard to Freedom of Expression

118.    On various occasions as particularized below, the Plaintiff’s instructors in the Education program, including the named defendants BELL, CANTOR and METZ and in addition a fourth instructor GEORGE BUSH (who is not a defendant in the present action) expressed displeasure with certain opinions expressed by the Plaintiff.

119.    In an assignment submitted to Professor Cantor in September of 2011, the Plaintiff was asked to write about his family background, personal beliefs, traditions and practices. Students were assured that the contents of the essay would be strictly confidential. In his essay the Plaintiff wrote comments which could be considered critical of another instructor and the President of the University. Subsequently, in a letter to the Deans of Education, Professor Cantor described the contents of the Plaintiff’s essay and expressed concern with them.

120.    On September 29^th 2011, the Plaintiff was attending a class instructed by Professor Bush in which that instructor criticized the class for certain behaviors. The Plaintiff expressed the opinion that the professor ought not to be criticizing the class, whereupon the instructor launched into a heated tirade directed against the Plaintiff, characterizing him inter alia as being disrespectful.

121.    In October 2011, the plaintiff was assigned by Professor Metz to do a presentation on Conservation of Momentum. In a discussion with the professor, the Plaintiff expressed disagreement with the professor’s recommended method of teaching “Conservation of Momentum”. Subsequently, Professor Metz reported the discussion to the Deans of Education, expressing disdain for  the Plaintiff’s position. Later, the Plaintiff presented the topic in class using his own preferred method, and was subsequently given a grade of 60%, including a failing grade for the “theory” component.

122.    In October 2011, Professor Bell was speaking in class about the purpose of education. The Plaintiff made a brief statement to the class expressing disagreement with the professor, but the professor did not reply. Subsequently, in a major assignent, the Plaintiff wrote about the earlier disagreement, elaborating on his position. He also identified several difficulties he had found with the curriculum and wrote about how he would deal with them. Professor Bell gave the Plaintiff a grade of 55% on the assignment, writing: “Too much effort went into finding fault with the curriculum, me, Prof. Metz, all U of W instructors, etc.”

123.    In November 2011, the Plaintiff became involved in an in-class disagreement with Professor Bush over how one might teach the concept of “moles” in Grade Eleven Chemistry. The professor expressed disdain for the Plaintiff’s opinion in front of the class, saying “Obviously you don’t know very much about chemistry”. On a subsequent term paper, the Plaintiff wrote about how he would teach moles in Grade Eleven Chemistry. He also identified a problem with one of the lab exercises included in the curriculum and proposed a means of rectifying the problem. Professor Bush gave him a failing grade on the term paper.

124.    On the same essay, students were asked to explain how their lesson plans reflected the Constructivist philosophy of education. The Plaintiff explained in his essay why he did not subscribe to the Constructivist ideology, and was give a mark of zero for that portion of the assignment.

125.    Subsequently the Plaintiff appealed his grade to the Departemental Committee. The Departmental Committee ratified the failing grade without giving reasons. The Plaintiff appealed to the Senate. Upon being pressed for reasons, the Departmental Committee revealed that they had not read the paper prior to ratifying Professor Bush’s failing grade. When the Plaintiff subsequently tried to assert his right to argue his case before the Senate Committee, his appeal was denied and the case closed.

126.    In November of 2011 Professor Metz invited a vendor of educational software to speak to the class. In a class discussion, the Plaintiff expressed reservations about the educational value of the vendor’s merchandise. In a subsequent meeting, Professor Metz complained to his colleagues and the Deans of Education that he had invited a guest “who was criticized (by the Plaintiff) in less than five”.

127.    In the same meeting, involving the four named instructors, the Deans of Education and the defendant WOLOSHYN, the following remarks were recorded concerning the Plaintiff:

a)    “all the time disagreeing with others”

b)    “expresses his contempt for everything and everyone”

c)    “a diatribe on curriculum and the dept.”

d)    “accused other instructors by name”

e)    “disparages instructors”

128.  In the final exam of Professor Bush’s course, which was an “open-book” exam, the Plaintiff explained why he did not bring the permitted material into the exam, and in doing so expressed negative opinions about the value of said material. Professor Bush gave him a grade of 50% on the exam. When the Plaintiff appealed the grade, Professor Bush characterised the appeal as a form of harassment, going so far as to seek a protective order preventing the Plaintiff from having any further contact with him. In his written application for the court order, Professor Bush quoted excerpts from the Plaintiff’s exam paper as described above in support of his application.

129.    The Plaintiff claims that his instructors gave him grades much lower than would otherwise have been warranted by the quality of the work because they disagreed with his opinions; and that to the extent that they did so in their capacities as employees and agents of the University, that the University thereby violated his right to freedom of thought, belief, opinion and expression as guaranteed by the Charter of Rights and Freedom, and he is therefore entitled to damages.

130.    The Plaintiff claims that his instructors disparaged and criticized him in front of the other students in the program because they resented his espressing opinions different from their own; and that by ultimately creating an atmosphere where the Plaintiff was unfairly characterised as a troublemaker and feared and resented by his classmates, they laid the grounds for his removal from the program and thereby violated his right to freedom of expression etc. as expressed in para 154 above.

131     The Plaintiff claims that the University revoked his sponsorship to the Conference of Student Teachers in Calgary because they wished to prevent him from expressing his opinions, and in doing so they violated his right to freedom of expression etc. as expressed in para 154 above.

132.    The Plaintiff claims that his instructors recommended, and the University carried out, disciplinary proceedings which culminated in his removal from the program in large measure because they wished to prevent him from continuing to express opinions contrary to their own; and that to the extent that they did so, the University violated his right to freedom of thought, belief, opinion and expression as guaranteed by the Charter of Rights and Freedoms, and he is therefore entitled to damages.

The Gory Details

In two more weeks I'll be in court arguing the University's Motion for Stay of Discovery. I filed my Brief just the other day. You can read it online here.

It's a really long brief but it's worth reading if you want to know exactly how the University has screwed me over since the day two years ago they removed me from the teaching practicum at Gordon Bell. What emerges is a picture of how they have relentlessly and shamelessly frustrated my right to disclosure, thereby making it impossible for me to answer the charges against me. The present motion, to put a hold on my right to oral discovery while they proceed with their Motions for Summary Judgment, is just a continuation of what they've been doing for the last two years.

I conclude my Brief with a kind of post-script, where I justify the fact that I'm pushing hard to move forward with my case. It's not exactly a legal argument, but I think it sums things up pretty well. I've reproduced it here for your enjoyment:

Epilogue (to the Plaintiff's Motions Brief)

84.       As a Canadian citizen of the Mosaic persuasion, the Plaintiff has frequent occasion, whether in Temple or in ordinary social situations, to encounter co-religionists  who are members of the legal profession, wherupon the Plaintiff has often taken advantage of the opportunity to discuss his experiences as a self-represented litigant.

85.       In one such conversation with a well-known Member of the Bar, a co-religionist of the Plaintiff whom we will hereinafter refer to as Mr. K, the Plaintiff expressed his indignation at learning of a recent case where it took twenty-two years from the time the action was launched until it was argued in Court. The Plaintiff recalls expressing his frustration using words similar to “the legal system is a farce”; whereupon Mr. K admonished him that it was not so; that the system was not “broken”, and it was more likely that lack of sufficient diligence on the part of counsel  was to blame for such inordinate delays of justice. Mr. K further expressed the opinion (or perhaps it was a boast) that working within the rules, he could get any case to trial in 18 months (or 24 at the most), provided he saw fit to devote his fullest efforts to that end.

86.       In the present case, the Defendants have frequently expressed resentment (as described in the foregoing) at the efforts they have had to exert in response to the Plaintiff’s actions. We, for our part, believe we are doing nothing more than using the Queen’s Bench Rules for their intended purpose; namely, the speedy and expeditious determination of justice. Perhaps it is commonly accepted within the Legal Profession that many of the “deadlines” mandated by the QB rules are not meant to be taken literally, but we do not feel bound to acquiesce to this state of affairs simply because it has become the norm. Indeed, given the age of the Plaintiff, if we were to allow this case to languish for twenty-two years before going to trial, the issues would most likely have become moot in the most definite sense of the word before then.

87.       We therefore feel fully justified in agressively taking up the challenge which Rocky has laid down before us: namely, to get our case to trial inside of two years. At the time of this filing it will have been thirteen months, so we feel we are still “on track” to make target. We urge the Court to respect our desires in this regard, even if it may seem that in practise “speedy justice” has become more the exception than the rule. 

ALL OF WHICH IS RESPECTFULLY SUBMITTED.

October ______ 2013                                              Martin Green

                                                                                  

The University Responds to the Mother of All Lawsuits

I told you recently how I had just served on my adversaries what I called the Mother of All Lawsuits. You can read the Statement of Claim here. Well, the University has now responded. Instead of filing a Statement of Defence, they have gone for the gusto and filed a Motion to Strike. You can read their Motion here.

Well, I'm not a lawyer, but I think they've made a bit of a mistake. I don't think they are going to succeed with their Motion to Strike, because they've made a mistake.

Or maybe I'm making a mistake. If I'm right, it's something a second-year Law Student should be able to spot. If I'm wrong...well, I guess I'll find out sooner or later. I know it's an awful lot of reading, but does anyone want to take up the challenge? I think I'll leave that hanging for now. There's plenty of other action taking place of the Civil front, and we'll talk some more about it when we return.

Send In The Clowns: Part 2

I told you how last winter Mr. Meronek made a big stink about how I supposedly hadn't served him properly with my Affidavit on his Motion for Summary Judgment. Well, I thought that was the end of the matter until about two weeks ago. In the meantime, his Motion had been argued before Master Berthaudin and dismissed with costs; subsequently, he filed a Notice of Motion to appeal the dismissal.

Actually, after the little encounter outside the Master's Chambers which I told you about the other day, it seems Mr. Meronek had had enough of me altogether; subsequently, he brought in Miss Mulholland, a young lawyer with his firm, to assist on the case, and it is Lindsay with whom I had been dealing ever since; in particular, it was Lindsay who had given me a copy of their Brief on their appeal of Berthaudin's ruling. I was therefore astonished upon reviewing the brief to read the following:

"Of additional concern to these defendants is that the Plaintiff, having specifically relied upon the documents in his Affidavit of Documents, refused to provide these Defendants with a copy of the documents, but at the hearing provided a copy of those documents to the Master. These defendants raised this concern at the hearing. Nevertheless, Master Berthaudin proceeded to hear the Motion notwithstanding that these defendants did not have access to the Plaintiff's material which the Master had before him."

What was especially astonishing to me was that they were making this argument without presenting any evidence to back it up. I don't think they can get away with that. I decided that I would, at the earliest opportunity, ask the Court to order opposing counsel to file evidence backing up the bizarre accusations concerning not only myself but Master Berthaudin's conduct. And by "evidence", I meant the transcript of our appearance where we argued the motion back in April.

The next time I saw Lindsay was just before our appearance on September 27th before Master Lee. I told her I was concerned that she had made those claims without filing evidence to back them up, and that I intended to ask the Master to order a transcript filed as evidence. Lindsay at first didn't understand; surely, I remembered introducing evidence from my Affidavit of Documents that she hadn't been given. "Of course you had those documents", I explained. "Those were the same Affidavits that Mr. Meronek made such a fuss over".

And then it dawned on me. Lindsay hadn't been brought into the case until after the little to-do over the Affidavits. When she told me that she had gone into court with nothing but a bundle of divider tabs and mini-affidavits, I understood what had happened. Mr. Meronek had simply ignored my email service and given Lindsay the supplemental package which I had dropped off at his office, the one where I told him if he didn't have a hole-punch he could send his people to my house and I would let them borrow mine.

When I explained this to Lindsay, she assured me she would go back to the office and get to the bottom of this. So I didn't raise it before Master Lee. I told her there was no reason for me to embarrass her before the Master on account of Mr. Meronek's "jackass behavior". I think she appreciated the heads-up.

Well, I didn't hear back from Lindsay the following week, so last Monday I sent the following email, addressed to her and Mr. Meronek:

Dear Counsel:

As I discussed with Lindsay prior to our last appearance, I wish to dispute your allegation that Master Berthaudin accepted evidence from me at our hearing on April 30th  which had not been previously disclosed to opposing counsel. Accrodingly, I am asking that you undertake to order the transcripts of that hearing and file them with the Court. (That would be with respect to your Appeal on Summary Judgment.)

If I do not hear from you by the end of this week, I will understand that you do not intend to order the transcripts and I will proceed accordingly. They are available from Transcript Services and estimated at 93 pp x 3.00/page = 279.00 plus GST.

Thank you for your consideration of this matter.

Marty Green

Lindsay wrote back the same day:

Mr. Green,

Please be advised that we will be filing an amended legal brief re: summary judgment appeal to a judge.  Our amended appeal brief will omit our position that the Defendants had not received your summary judgment documents.  For efficiency, so the Defendants can simultaneously respond to any of your legal arguments if necessary, our amended appeal brief will be filed once we have received your responding brief,.

Please contact me if you have any questions.

Regards,

Lindsay M. Mulholland, B.A., LL.B.

Well, I did not find this entirely satisfactory. I thought that having made an improper allegation, it wasn't enough to simply file an amended brief in which the allegation was "omitted". She really ought to withdraw it explicitly. So I wrote back:

Lindsay, I feel I ought to tell you I am not entirely satisfied with the outcome whereby you are able to quietly withdraw the allegation without repercussion. I am not sure what leverage I actually have in terms of, say, putting you to the expense of ordering the transcript, but I am still considering my options. Pehaps you feel secure in your position and wish to take the attitude, "go ahead, do your worst". I don't object to that; as you understand, I will do whatever I feel is in my best interests, and I expect you to do the same for your clients.

To make a long story short, I feel I caught you with your pants down on this matter and would still like to squeeze some more mileage if possible out of it. The most straightforward outcome, from my point of view, would be for you to file the transcripts and follow up with a supplementary brief which explicitly admits that you were in error in your original argument (rather than merely "omitting" it). As I said, I really don't know what rights I have in this matter, but if I don't hear from you I hope you understand that I will  be considering my options.

Respectfully

Marty Green

Lindsay replied the following day:

In response to your comments below I can provide the following information:

-        The confusion concerning which evidence you were relying on before Master Berthaudin arose due to the fact that your Affidavit, sworn January 23, 2013, indicated that you were relying on “the exhibits included herein are the same documents as those identified in my affidavit of documents as item 15(j)(Outbox) under the heading “Email Correspondence with Terri Einarson”.

-        The hardcopy which you served on the Defendants’ counsel did not include the exhibit documents you were relying on, rather it provided Registrar stamped cover pages.

-        You have since informed us that the full exhibit documents you were relying on were served via email.  The documents attached via email, however, were not court stamped.  Ultimately, there was no way to determine whether the documents you served via email were in fact the same documents served with the court, as they were not officially marked exhibits.  It is arguable whether your exhibits fully complied with the QB Rules, however, given the number of issues already pending, the Defendants are choosing not to bring this argument before the Court.

So she was claiming that it was my fault after all...that I served her with hard copy, and subsequently tried to claim the documents were served as email attachments. She then says it is "arguable" whether my exhibits complied with the QB rules. And she was refusing to file the transcripts. Well, it seems to me if opposing counsel wished to "argue" the admissibility of my affidavits, Mr. Meronek should have done so when he got my package with the cover letter about how he could borrow my hole punch. Instead, he apparently got himself in a big snit and sent Lindsay into court on his behalf not even knowing about the whole brouhaha over the email attachments. And now here she was holding the can!

So I sent her back the following letter:

Lindsay, with regard to the unsupported claim in your Motions Brief, as I explained to you just before we saw Master Lee, I was giving you advance notice of the situation because I didn't want you to be personally embarrassed on account of what I think I characterised as the "jackass behavior" of Mr. Meronek.  So I am disappointed that your firm is still taking the position that there was anything improper about my service of Affidavits on you last January. Under the circumstances, I hope you will understand that I cannot acquiesce to a situation where you can serve me via email (which I have been accepting as a courtesy to you), while my service by email is considered improper. I will therefore no longer be accepting service via email. Please serve me in the future according to QB rules as a self-represented party.

I regret having to write this letter.

Marty Green

And then it gets interesting. But that's a story that will have to wait for another day....

Send In the Clowns: Part 1

I told you that I was going to explain more about my "Mother of All Lawsuits", but in the meantime a little sideshow has been developing over the last few days which warrants a story of its own. It's really the sequel of a little story that played out last winter, but which I declined to blog about on the theory that I ought to try and maintain proper relations with opposing counsel. Well, that ship seems to have sailed, so I might as well tell the whole story. So let's go back to January, when Mr. Meronek filed his Motion for Summary Judgment, followed shortly by the Affidavit of Evidence filed by U of W Registrar Colin Russell.

When we appeared before the Master on the Uncontested List, I naturally stated I would be opposing the motion; so the Master moved us to the Contested List, scheduled out next appearance for the first week in February, and instructed me to file my own Affidavit of Evidence and serve it on opposing counsel before then. I got right to work on my Affidavit, and had it ready by the 21st of January. Now, up to this point I had been preparing all my documents in triplicate, taking them down to the Court to have them stamped and sworn, and then distributing copies to opposing counsel. But this time, Mr. Meronek had served me his motion via email, including the Russell Affidavit which was quite massive and had at least ten attachments. This put me to an inconvenience in terms of printing it out and binding it. So I thought I should return the favor and serve my Affidavit the same way, by email. Let Mr. Meronek print it out using his paper and ink.

There was a small complication, however: In his filings, Mr. Meronek had sworn out his affidavits in-house and PDF'd them into his email package, whereas I had to go to the court to get mine sworn, which might have set me back a few days. I wanted Mr. Meronek to have my affidavits as soon as possible, so by the time we appeared again before the Master, he wouldn't have any excuse for not having gotten started on his Brief. The sooner that was in, the sooner we'd get to argue the motion, and I didn't want any delays. So on the 15th of January I sent him my Affidavit via email as a doc file, with the following cover letter, acknowledging that I these were unofficial copies:

Dear Mr. Meronek:

 

Please find attached my Affidavit of Evidence, to be followed shortly in consecutive emails by the associated Exhibits. You will find the listing of Exhibits in the first Exhibit (Exhibit A) after which the remaining exhibits are numbered numerically, for reasons I hope will be understood. I will be filing them in the next day or so; please let me know if you wish me to fax you the front page with the Court's stamp as confirmation of filing. I look forward to meeting you in Court on February the 5th and perhaps you will have had time to prepare your Brief by then.

 

Martin Green

 
To make sure everything was perfectly clear, I followed up with the following:

In case you weren't sure, each exhibit consists of the email plus any attachments. Please let me know if there is any question what goes where.

 Mr. Meronek did not reply. A few days later I filed the official copies, stamped, sworn and bound, with the court, and three weeks later we appeared before Master Sharpe. The Master began by asking if all affidavits had been filed. "No, Your Honor", began Mr. Meronek. "The Material we received from Mr. Green was incomplete."

I couldn't believe it. He was complaining that I hadn't sent the stamped mini-Affidavits that go with each exhibit. I told him he'd had the material for three weeks already...why was he waiting until now, when we were in front of the Master, to make this complaint? Mr. Meronek bristled indignantly: "Mr. Green is fully aware that I have been out of the country for the last three weeks." As though he thinks I am being sent regular updates on his travel arrangments!

Master Sharpe was unimpressed by all this, and after accepting my undertaking to correct the deficiency, went on to give Mr. Meronek a deadline for filing his Motions Brief. Later, outside the courtroom, I approached Mr. Meronek. The conversation went something like this:

"So can I send you the stamped mini-affidavits for each of the exhibits?"

"I want exactly what you gave the Court."

" And you already have everything except the stamped mini-affidavits. So I can drop them off at your office?"

"I want exactly what you gave the Court."

"In other words, just the mini-affidavits?"

"I want exactly what you gave the Court."

Well, I'd had enough of this. "I don't give a damn what you want", I told him, "you'll get exactly what I give you." He strode off indignantly, and I went home to prepare a package for him. Two days later, having dropped of the package at his office, I sent him the following email:

Dear Mr. Meronek:

I trust you received the material which I dropped of at your office yesterday. I believe this corrects the deficiencies you identified on Tuesday before the Master. If you have any further difficulties with the material, please contact me.

 

Please let me know if Mr. Mackwood needs me to provide him with the updates as well.

marty green

 

What was in the package I sent him? I thought I did a pretty nice job of it. There were actually twenty-one attachments, so I sent him twenty-one numbered divider tabs, twenty-one mini-affidavits, and the first page of each of the twenty-one attachments, so there would be no confusion as to which divider tab and mini-affidavit went with which attachment. I urged him to contact me if he had any trouble figuring out how to assemble the material I had already sent him via email with the dividers and affidavits, telling him that the copy filed with the Court had been bound with Cirloc binder rings. I concluded my cover letter by telling him he could pick up the binder rings at Staples, and if he didn't have a hole-puncher at his office, his people were welcome to come to my home and use my hole-puncher.

And that's where matters rested until last week.

The Mother of All Lawsuits

On several occasions I've told you how I messed with my adversaries by suing them not for kicking me out of University, but for kicking me out of my teaching practicum. Well, now the other shoe has dropped. Just before the start of my criminal trial, I served opposing counsel with what I am calling the Mother of All Lawsuits. You can read the Statement of Claim, all 132 paragraphs of it, online here.

I have taken some flak over the length of the Statement of Claim, but I think I've done it right. It's a long and involved claim, and it needs to be pleaded very carefully. What I'm going to do today is break it down by paragraphs to explain why I've pleaded it as a have.

But before I get to that I should talk about the stroke-throughs and underlines. The claim was originally filed on April 29th. Subsequently I had a situation where I had filed a suit against Professor Bush for slander, and opposing counsel had filed a Motion to Strike. I wasn't too worried about this until I started preparing my response, and I was pretty horrified to learn how hard it is to win a case for slander. Part of this is because slander is verbal as opposed to libel which is written, and the law requires you to be very exact with regard to the words pleaded. That's almost impossible in a slander case. But along the way, I learned some things about the particular difficulties associated with pleading any kind of defamation action, and I realized that I was vulnerable not only on the Bush case, but on the present case, the one against the University for kicking me out of the program. That's when I rewrote my claim completely. The underlines and stroke-throughs reflect those amendments, as required by the Queen's Bench rules. So if you're interested and sufficiently motivated, you can go through it and compare the "before" and "after" versions. I think the present version is much more robust, and in a way I have Professor Bush to thank for that.

The other major change between the spring and the fall was I decided to add a Charter claim for Freedom of Expression. You know, professors are always giving students bad marks because the student argues for a different point of view than the professor wants to hear. But it's almost impossible to convert that into a claim for damages under Freedom of Expression. Almost but not quite. If anyone can do it, I think I can. And I'm prepared to argue it  through to the bitter end, and go down fighting if necessary. It should be interesting.

Most of the remaining changes were with regard to just the overall length. I tried to cut the background narrative down to the bare minimum. Regardless, it still came to 47 paragraphs. Oh, there was one more thing: I had to drop the complaint of Conspiracy to Injure. I'm not entirely happy about this. The problem is that according to case law, you can't "tack on" a claim of Conspiracy to what is otherwise a case of defamation. It's a general rule that I felt shouldn't apply to my particular case, but after a careful review, I decided I had put enough into my claim without giving myself the additional burden of overcoming one more obstacle. So I took it out; and with it, I had to drop Dean of Education John Anchan as one of the defendants.

Which brings us to the claim. Let's go through it by paragraph and see what it consists of.

Paragraph 1: This is where you state that you are asking for damages.

Paras. 2-10: This is where I name the defendants.

Paras. 11-58: This is where I give the factual background. And then I get into what I am claiming for. Actually, at this point, we can let my Statement of Claim speak for itself:

The Plaintiff’s Claims

59.       The Plaintiff claims that in their written complaints against the Plaintiff, the defendants Bell, Cantor and Metz did maliciously defame and libel the Plaintiff, as set out in paras. 65-75 below.

60.       Further, or in the alternative, the Plaintiff claims that in fostering and prosecuting the said written complaints and failing to allow the Plaintiff adequate opportunity to respond to the allegations against him, the University did variously engage in a conspiracy to injure, an intentional breach of duty of care, a breach of contract and a denial of due process as set out in paras  76-97  below.

61.      The Plaintiff claims that in implementing the trespassing order against the Plaintiff, the University and Colin Russell did maliciously defame the plaintiff as set out in paras. 98-106 below.

62.       The Plaintiff claims that insofar as the defendants actions were motivated by a belief that the plaintiff suffered from a mental disability, that they violated his Charter Rights as set out in paras 107-111  below.

63.       The plaintiff claims that in her written complaint against the plaintiff, the defendant JANE DOE did maliciously defame and libel the plaintiff, as set out in paras. 112-117 below.

64.    The Plaintiff claims that insofar as the defendants’ actions were motivated by a desire to silence the Plaintiff’s right to express his opinions, that they violated his Charter Rights as set out in paras 118-131 below.

And that's it. Six separate causes of action, all rolled up in one big Statement of Claim. When we return, we'll have more to say about the various claims.