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IN THE MATTER OF the Libel and Slander Act, R.S.O. 1990, c. L.

12

AND IN THE MATTER OF an intended action

BETWEEN:

CAMPAIGN RESEARCH INC. Plaintiff and

PATRICK MARTIN Defendant

________________________________________________________ NOTICE ________________________________________________________

TAKE NOTICE that pursuant to section 5(1) of the Libel and Slander Act, R.S.O. 1990, c. L.12, the Plaintiff hereby complains of a false and malicious public broadcast by the Defendant of and concerning the Plaintiff. In particular, the Plaintiff complains of comments made by the Defendant on the CTV television program Question Period on or about February 26, 2012 (the February 26, 2012 Broadcast) and at such further times and on such further dates as the Plaintiff is currently unaware.

Without limiting the generality of the foregoing, the Plaintiff complains in particular of the following words in the February 26, 2012 Broadcast:

(a) Theres one large research company thats was guilty of these mischief and nuisance calls in Irwin Cotlers riding and its called Campaign Research, one of them is the Vice-President of the Conservative Party of Canada, hes now actually the President of the Conservative Party of Ontario, the other is a guy named Nick Kouvalis, who is a senior strategist for the Conservative Party. Thats the kind of sized company that would have the organizational capacity to undertake such a massive, monumental election fraud across the country.

Without limiting the generality of the foregoing, the words complained of in the February 26, 2012 Broadcast in their natural and ordinary meaning, and by innuendo, meant and were understood to mean, inter alia, that:

(a) The Plaintiff was found guilty of a criminal offence with respect to phone calls made in the federal electoral district of Mount Royal, Quebec; and

(b) The Plaintiff has engaged in activities which constitute election fraud.

The words complained of in the February 26, 2012 Broadcast and the innuendos of and concerning the Plaintiff are malicious, false, vicious, unfair and seriously defamatory of the reputation of the Plaintiff. The words complained of in the February 26, 2012 broadcast were intended by the Defendant to harm the Plaintiff within the communities in which it carries on business.

The Plaintiff hereby demands that the Defendant retain in safekeeping any and all materials upon which the February 26, 2012 Broadcast was based.

AND TAKE NOTICE that this Notice is given to you pursuant to the provisions of the Libel and Slander Act, R.S.O. 1990, c. L.12.

The Plaintiff hereby gives notice pursuant to the Courts of Justice Act that it will be claiming for pre-judgment interest from the date of this Notice to the date of judgment.

DATED at Ottawa this 27th day of February, 2012. The Plaintiff:

Campaign Research Inc. 8 York St, 2nd Floor Ottawa, Ontario K1N 5S6 Aaron Wudrick LSUC No.: 55421L Tel.: (613) 884-8251 TO: PATRICK MARTIN by email to pat.martin@parl.gc.ca

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