2002 Evidence History

Year #13 – 2002

[283] January 7 2002
ZEP History - 69: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 114: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[284] January 11 2002
ZEP History - 70: ENIO telephone conversation with Doris (?) of CTN for EFX.
Question ZEP - 115: Why and what is ENIO talking about to Doris (?) of CTN for EFX? – [Why is Doris’ name not complete?]
ZEP History - 71: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 116: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]

[285] January 14 2002
ZEP History - 72: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 117: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[286] February __ 2002
Question EFX - 346: “AFFIDAVIT OF DOCUMENTS” by Patricia H. Solomchuk (EFX) and Schwartz of CTN for EFX and Commissioner for Oaths.
Question EFX - 347: Why is RNC’s copy of Affidavit of Documents “Not Signed” by any of three signatures required on the documents?
Question EFX - 348: Why is RNC’s copy of Affidavit of Documents “Undated” and partially written as February 2002?
Question EFX - 349: Why is EFX – “Affidavit of Documents” and BNS – “Affidavit of Documents”
Question EFX - 350: Both Written Oaths almost written exactly the same?
Question EFX - 351: Did Patricia H. Solomchuk (EFX) “conduct a diligent Search of Bank Records” and “Write Oath” or did “someone else”?
Question EFX - 352: Why is the “Affidavit of Documents” copy “December 19 2001” and “almost exact copy unsigned in February 2002 by EFX”?
Question EFX - 353: Did BNS assemble “EFX Production Brief” using the same coloured “Pink Paper” as dividers?
Question EFX - 354: Section B (a) (b) and Section C (1) need to be examined by the courts for collusion by BNS and EFX.

[287] February 4 2002
ZEP History - 73: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 118: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[288] February 19 2002
ZEP History - 74: ENIO sends correspondence to Buhler of BLG for BNS.
Question ZEP - 119: Why did RNC not receive a copy of this correspondence sent to Buhler of BLG for BNS?

[289] February 20 2002
ZEP History - 75: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 120: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[290] February 22 2002
ZEP History - 76: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 121: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[291] February 25 2002
ZEP History - 77: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 122: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
ZEP History - 78: ENIO received and reviewed correspondence from Schwartz of CTN for EFX.
Question ZEP - 123: Why did RNC not receive a copy of this correspondence from Schwartz of CTN for EFX?

[292] February 28 2002
ZEP History - 79: ENIO meeting with assistant.
Question ZEP - 124: Who is the assistant at the meeting with ENIO?
Question ZEP - 125: Why did ENIO need to meet with an assistant?
Question ZEP - 126: When was the assistant hired by ENIO and ZEP?
Question ZEP - 127: Why was RNC not informed about the assistant?
Question ZEP - 128: Where did the assistant previously work to bring skills to RNC’s lawsuit?
Question ZEP - 129: Why was the assistant updated on RNC’s lawsuit without permission from RNC?
Question ZEP - 130: What was the meeting between ENIO and the assistant about?
Question ZEP - 131: Why were the discoveries not in February 2002 as earlier stated by ENIO’s letter dated December 6 2001?
Question ZEP - 132: Why did ENIO delay the litigation and then hire a new assistant Pearl Rombis LL.B. to take over RNC’s litigation?
ZEP History - 80: ENIO delays litigation procedures to unjustly hire an assistant so that ENIO can abandon the litigation discoveries.
ZEP History - 81: ENIO review documents.
Question ZEP - 133: What documents did ENIO review?
Question ZEP - 134: How many documents are there?
ZEP History - 82: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 135: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]
ZEP History - 83: ENIO has telephone conversation with Nartub Byekkers.
Question ZEP - 136: Who is Nartub Byekkers?
Question ZEP - 137: Why is ENIO talking to Nartub Byekkers about RNC’s litigation?
Question ZEP - 138: What is ENIO talking about to Nartub Byekkers?
Question ZEP - 139: Why was RNC not told about ENIO and Nartub Byekkers conversation?
ZEP History - 84: ENIO review of file, pleadings and correspondence.
Question ZEP - 140: What files did ENIO need to review?
Question ZEP - 141: What pleadings did ENIO need to review?
Question ZEP - 142: What correspondence did ENIO need to review?
ZEP History - 85: ENIO sends correspondence to Buhler of BLG for BNS.
Question ZEP - 143: Why did RNC not receive a copy of this correspondence to Buhler of BLG for BNS?
ZEP History - 86: ENIO sends correspondence to Schwartz CTN for EFX.
Question ZEP - 144: Why did RNC not receive a copy of this correspondence to Schwartz CTN for EFX?

[293] March 1 2002
ZEP History - 87: ENIO telephone conversation with Schwartz CTN for EFX.
Question ZEP - 145: Why and what is ENIO talking about to Schwartz CTN for EFX? – [There should be no telephone communications]
ZEP History - 88: ENIO preparation of correspondence to RNC
Question ZEP - 146: What correspondence needs preparation for RNC?
ZEP History - 89: ENIO review affidavit.
Question ZEP - 147: What affidavit does ENIO need to review?

[294] March 4 2002
ZEP History - 90: ENIO sends correspondence to Buhler of BLG for BNS.
Question ZEP - 148: Why did RNC not receive a copy of this correspondence to Buhler of BLG for BNS?
ZEP History - 91: ENIO sends correspondence to Schwartz CTN for EFX.
Question ZEP - 149: Why did RNC not receive a copy of this correspondence to Schwartz CTN for EFX?

[295] March 5 2002
ZEP History - 92: ENIO reviews client file material.
Question ZEP - 150: What file material did ENIO review?

[296] March 6 2002
ZEP History - 93: ENIO preparation of authorizations.
Question ZEP - 151: What authorizations were prepared?
ZEP History - 94: ENIO gives instructions to law clerk
Question ZEP - 152: Who is the law clerk?
Question ZEP - 153: What instructions did ENIO give to law clerk?
ZEP History - 95: ENIO correspondence to RNC.
Question ZEP - 154: Why did RNC not receive a copy of this correspondence from ENIO?
ZEP History - 96: ENIO preparation of Production Memorandum / Brief.
Question ZEP - 155: Why did ENIO prepare Production Briefs on March 6th 2002 and not give them to RNC until May 16th 2002?
ZEP History - 97: ENIO research.
Question ZEP - 156: What did ENIO need to research?

[297] March 7 2002
ZEP History - 98: ENIO files an Amended Statement of Claim against EFX and BNS.
Question ZEP - 157: Why does ENIO need to file an amended statement of claim against EFX and BNS?
ZEP History - 99: ENIO mails correspondence to RNC regarding the Amended Statement of Claim.
Question ZEP - 158: What changed from the original Statement of Claim against EFX and BNS?
RNC History - 428: RNC’s mental state interferes with his understanding of the legal stuff so RNC trusts ENIO to be diligent in his duty.

[298] March 14 2002
ZEP History - 100: ENIO has telephone conversation with EFX’s office.
Question ZEP - 159: Who is ENIO communicating to at EFX’s office?
Question ZEP - 160: Why is ENIO communicating to this person at EFX’s office?
Question ZEP - 161: What is ENIO communicating to this person at EFX’s office?

[299] March 15 2002
RNC History - 429: RNC meets Pearl Rombis (Rombis) ZEP.
ZEP History - 101: ENIO / Rombis 1st meeting with RNC.
RNC History - 430: RNC receives from ENIO – the Amended Statement of Claim against EFX and BNS.

[300] March 18 2002
ZEP History - 102: ENIO telephone call to Len Baker (CIBC).
ZEP History - 103: Len Baker (CIBC) states willing to give letter of the denial.
Question ZEP - 162: Where is document?
ZEP History - 104: ENIO meeting with RNC
ZEP History - 105: RNC’s telephone message to Adrianna Moukas EFX requesting his credit report that was unavailable to the TD bank.
ZEP History - 106: ENIO sends correspondence to Ministry of Health.
ZEP History - 107: ENIO telephone conversation from RNC

[301] March 19 2002
ZEP History - 108: ENIO received and reviewed correspondence from RNC written by Mrs. Moukas (EFX).
Question ZEP - 163: Why is this important key evidence (correspondence) ignored by ENIO and not submitted as evidence against EFX?
Question EFX - 355: Adrianna Moukas (EFX) mails letter refusing to give RNC his EFX credit report.
RJC History - 189: RNC tried to retain his credit report directly from Mrs. Moukas because Bob Pinkney, manager of TD Canada Trust could not pull up RNC’s credit report when RNC was applying for a 2nd mortgage.
Question EFX - 356: Once again, EFX causes another denial for unfounded reasons.
RJC History - 190: This causes RNC to request for 2nd mortgage help from ENIO.
Question EFX - 357: Why was RNC’s credit report unavailable to be viewed by Bob Pinkney of TD Canada Trust?
Question EFX - 358: Why was RNC not told that his credit report was inaccessible to anyone requesting to view it?
Question EFX - 359: Why did Adrianna Moukas (EFX) continue to refuse RNC’s request for his credit report?
Question EFX - 360: EFX contravenes The Consumer Reporting Act for lack of communicating to RNC of the prior and current freeze of credit report.
RNC Claim - 365: Statutory Liability: A breach or violation of statute
RNC Claim - 366: Product Liability: Allows injured party financial compensation from the manufacturer or seller of a product.
RNC Claim - 367: Strict Liability: A false bad credit rating lowers credit score proving defendant’s object caused damage.
RNC Claim - 368: Professional Liability: A breach of duty owed in a professional capacity in connection with the firm’s business.
RNC Claim - 369: Vicarious Liability: (e/s) The defendant(s) are negligent for actions and/or inactions with my credit report and information.
RNC Claim - 370: Vicarious Liability: (e/s) The defendant(s) are negligent for false, inaccurate and missing information on my credit report.
RNC Claim - 371: Vicarious Liability: (r/c/t/o) The defendant(s) are negligent for their actions and/or inactions causing damage to or from others.
Claim vs EFX - 502 Negligence - - For telling untruths and evasion from truth forcing this matter to go to court for RNC to protect his innocence.
Claim vs EFX - 503 Negligent Infliction of Emotional Distress - - There is no reason why EFX can not correct my name – if there is – what is it?
Claim vs EFX - 504 Intentional Infliction of Emotional Distress - - EFX knows RNC wants his legal name back – EFX is unfoundedly malice.
Claim vs EFX - 505 Breach of Fiduciary Duty - - EFX has a duty to obtain, store and disclose the best possible most accurate credit information.
Claim vs EFX - 506 Breach of Contract - - A presumed agreement to disclose accurate non-false credit information about that person from EFX.
Claim vs EFX - 507 Breach of Trust - - Consumers have no choice but to put their faith and trust in corporations to correct their reporting errors.
Claim vs EFX - 508 Breach of Confidence - - Break-down of EFX credit reporting system shows the apparent weakness in the financial industry.
Claim vs EFX - 509 Breach of Promise - - EFX breached promise #10 (3rd time) causing distress and panic over believed repeated credit report errors.
Claim vs EFX - 510 EFX is in Contravention of The Consumer Reporting Act Rule 8(1)(b), Rule 9(1), 13(1), 23(1), 23(2).
Claim vs EFX - 511 EFX is in Contravention of The Personal Information Protection Act Rule 9 (33) b.
Claim vs EFX - 512 EFX is in Contravention of The Personal Information Protection and Electronic Documents Act Rule 4.6.1, 4.6.3, 4.9.4, 4.9.5.

[302] March 27 2002
ZEP History - 109: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 164: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?

[303] March 28 2002
ZEP History - 110: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 165: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
ZEP History - 111: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 166: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]

[304] April 5 2002
ZEP History - 112: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 167: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
ZEP History - 113: ENIO meeting with associate.
Question ZEP - 168: Who is the associates?
ZEP History - 114: Rombis / Serino send correspondence to RNC - re: Gathering documents for evidence.
ZEP History - 115: ENIO sends correspondence to Buhler of BLG for BNS.
Question ZEP - 169: Why did RNC not receive a copy of this correspondence to Buhler of BLG for BNS?

[305] April 19 2002 – New Interim Statement 14667/02
ZEP History - 116: ENIO reviews client file material.
Question ZEP - 170: What file material did ENIO review?

[306] April 29 2002
ZEP History - 117: ENIO reviews letter from RNC
Question ZEP - 171: What letter did ENIO review?
ZEP History - 118: ENIO reviews client file material.
Question ZEP - 172: What file material did ENIO review?

[307] April 30 2002
ZEP History - 119: ENIO reviews client file material.
Question ZEP - 173: What file material did ENIO review?

[308] May 7 2002
ZEP History - 120: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 174: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
ZEP History - 121: A two day examination for discoveries was set for June 3rd and 4th of 2002.
Question ZEP - 175: Why did ENIO delay the discoveries originally said to be in December 2001 moved to February 2002 then June 2002?
ZEP History - 122: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 176: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]

[309] May 8 2002
ZEP History - 123: ENIO received and reviewed correspondence from Schwartz of CTN for EFX.
ZEP History - 124: Schwartz states that ENIO is 2 months late with Production Briefs. - [Lack of Due Diligence]

[310] May 9 2002
ZEP History - 125: ENIO mails Interim Statement of Account No. 14558/02 for $5202.87. [July 23 2001 – May 9 2002]

[311] May 10 2002
ZEP History - 126: ENIO received and reviewed correspondence from EFX.
Question ZEP - 177: Why from EFA and not from Schwartz CTN for EFX?
ZEP History - 127: ENIO faxes correspondence to RNC regarding correspondence from Schwartz of CTN for EFX dated May 8 2002.
ZEP History - 128: Serino phone RNC and demands a $1,000.00 payment for disbursements.
RNC History - 431: RNC gives Serino a CIBC Visa number for a $1,000.00 payment. [Payment #5 = $1,000.00 = Total $4398.92]

[312] May 13 2002
ZEP History - 129: ENIO received and reviewed correspondence from Len Baker of the CIBC.
Question ZEP - 178: Why did RNC not receive a copy of this correspondence from Len Baker (Baker) of CIBC?
Question ZEP - 179: Why did ENIO not subpoena all evidence and witnesses from the CIBC including Baker and Sautner of the CIBC?
Question ZEP - 180: Why did ENIO fail his duties as counsel showing a lack of due diligence in the collecting evidence and witnesses?

[313] May 14 2002
ZEP History - 130: ENIO / Rombis 2nd meeting with RNC.
ZEP History - 131: ENIO Preparation of memorandum.
ZEP History - 132: ENIO amends Affidavit of Documents.
Question ZEP - 181: Why and what did ENIO need to amend in the Affidavit of Documents?

[314] May 15 2002
ZEP History - 133: ENIO / Rombis 3rd meeting with RNC to swear Affidavit of Documents.
ZEP History - 134: ENIO telephone conference with OHIP.

[315] May 16 2002
ZEP History - 135: ENIO / Rombis received and reviewed correspondence from Buhler of BLG for BNS regarding the discovery dates.
ZEP History - 136: Rombis 4th meeting with RNC regarding Examination for Discoveries on June 3 2002 and June 4 2002.
ZEP History - 137: RNC receives all 3 production briefs from all 3 parties 19 days before the discoveries.
ZEP History - 138: Rombis ask RNC to examine EFX and BNS production briefs and give her a report on them.
ZEP History - 139: Rombis (ZEP) receives and reviews correspondence from Buhler of BLG for BNS regarding lack of Production Brief.
ZEP History - 140: Rombis (ZEP) faxes correspondence to RNC regarding May 16 2002 correspondence from Buhler of BLG for BNS

[316] May 17 2002
ZEP History - 141: ENIO sends correspondence to CTN for EFX.
Question ZEP - 182: Why did RNC not receive a copy of this correspondence to CTN for EFX?
Question ZEP - 183: Who did ENIO send correspondence to at CTN for EFX?
ZEP History - 142: ENIO sends correspondence to BLG for BNS.
Question ZEP - 184: Why did RNC not receive a copy of this correspondence to BLG for BNS?
Question ZEP - 185: Who did ENIO send correspondence to at BLG for BNS?
ZEP History - 143: ENIO reviewing Rouge Valley Health Clinical notes.

[317] May 21 2002
ZEP History - 144: ENIO received and reviewed correspondence from BLG for BNS.
Question ZEP - 186: Why did RNC not receive a copy of this correspondence from BLG for BNS?
Question ZEP - 187: Who did ENIO receive correspondence from BLG for BNS?
ZEP History - 145: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 188: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]
ZEP History - 146: ENIO reviews client file material.
Question ZEP - 189: What file material did ENIO review?

[318] May 22 2002
ZEP History - 147: ENIO telephone conversation with RNC.
ZEP History - 148: ENIO telephone conversation with Dr. Malek’s office.
ZEP History - 149: ENIO telephone conversation with Dr. Malek’s office.
ZEP History - 150: ENIO reviews pleadings.
Question ZEP - 190: What pleadings does ENIO review?
ZEP History - 151: ENIO prepares for examination for discovery.
Question ZEP - 191: What does ENIO prepare for examination for discovery?

[319] May 24 2002
ZEP History - 152: ENIO completing reviewing of hospital notes.
ZEP History - 153: ENIO reviewing OHIP summary.
ZEP History - 154: ENIO reviewing clinical notes from Dr. Boutros.
ZEP History - 155: ENIO prepares for Examination of Discovery.
ZEP History - 156: ENIO prepares consent order to Amend Statement of Claim.
Question ZEP - 192: Why is a consent form needed for another Amended Statement of Claim?
Question ZEP - 193: Why is there another Amended Statement of Claim?
Question ZEP - 194: What changed from the last Amended Statement of Claim?
Question ZEP - 195: Was consent given by defendants for another Amended Statement of Claim?
ZEP History - 157: ENIO prepares for Examination of Discovery.

[320] May 27 2002
ZEP History - 158: ENIO telephone conversation with Dr. Boutros’ office.
ZEP History - 159: ENIO sends correspondence to Dr. Malek’s office.
Question ZEP - 196: Why did RNC not receive a copy of this correspondence to Dr. Malek’s office?
ZEP History - 160: ENIO sends correspondence to CTN for EFX.
Question ZEP - 197: Why did RNC not receive a copy of this correspondence to CTN for EFX?
Question ZEP - 198: Who did ENIO send correspondence to at CTN for EFX?
ZEP History - 161: ENIO sends correspondence to BLG for BNS.
Question ZEP - 199: Why did RNC not receive a copy of this correspondence to BLG for BNS?
Question ZEP - 200: Who did ENIO send correspondence to at BLG for BNS?
ZEP History - 162: ENIO prepares and serves Notices of Examination.
ZEP History - 163: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 201: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]
ZEP History - 164: ENIO telephone conversation with Schwartz CTN for EFX.
Question ZEP - 202: Why and what is ENIO talking about to Schwartz CTN for EFX? – [There should be no telephone communications]
ZEP History - 165: ENIO telephone conversation with Dr. Malek’s office.

[321] May 28 2002
ZEP History - 166: ENIO / Rombis meeting with RNC. [There was no meeting - RNC was unavailable due to Cooper v. Tardis case]
ZEP History - 167: ENIO telephone conversation with Buhler of BLG for BNS.
Question ZEP - 203: Why and what is ENIO talking about to Buhler of BLG for BNS? – [There should be no telephone communications]
ZEP History - 168: ENIO received and reviewed correspondence from BLG for BNS.
Question ZEP - 204: Why did RNC not receive a copy of this correspondence from BLG for BNS?
Question ZEP - 205: Who did ENIO receive correspondence from BLG for BNS?
ZEP History - 169: ENIO sends correspondence to CTN for EFX.
Question ZEP - 206: Why did RNC not receive a copy of this correspondence to CTN for EFX?
Question ZEP - 207: Who did ENIO send correspondence to at CTN for EFX?
ZEP History - 170: ENIO sends correspondence to BLG for BNS.
Question ZEP - 208: Why did RNC not receive a copy of this correspondence to BLG for BNS?
Question ZEP - 209: Who did ENIO send correspondence to at BLG for BNS?

[322] May 29 2002
ZEP History - 171: ENIO receives correspondence from CTN for EFX.
Question ZEP - 210: Why did RNC not receive a copy of this correspondence from CTN for EFX?
Question ZEP - 211: Who did ENIO receive correspondence from CTN for EFX?
ZEP History - 172: ENIO received and reviewed correspondence from Schwartz of CTN for EFX.
Question ZEP - 212: Why did RNC not receive a copy of this correspondence from Schwartz of CTN for EFX?

[323] May 30 2002
RJC History - 191: RNC finish his first quick examination all production briefs and give report to Pearl Rombis.
ZEP History - 173: ENIO / Serino / Rombis #5 meeting with RNC.
ZEP History - 174: RNC gave notes with questions about EFX and BNS production briefs.
RNC History - 432: RNC was told by ENIO “It is not necessary for me (ENIO) to attend discoveries” – RNC did not like what he heard!!!

[324] May 31 2002
ZEP History - 175: ENIO sends correspondence to CTN for EFX.
Question ZEP - 213: Why did RNC not receive a copy of this correspondence to CTN for EFX?
Question ZEP - 214: Who did ENIO send correspondence to at CTN for EFX?
ZEP History - 176: ENIO sends correspondence to BLG for BNS.
Question ZEP - 215: Why did RNC not receive a copy of this correspondence to BLG for BNS?
Question ZEP - 216: Who did ENIO send correspondence to at BLG for BNS?
ZEP History - 177: ENIO telephone conversation with Schwartz CTN for EFX.
Question ZEP - 217: Why and what is ENIO talking about to Schwartz CTN for EFX? – [There should be no telephone communications]
ZEP History - 178: ENIO received and reviewed correspondence from Buhler of BLG for BNS.
Question ZEP - 218: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
ZEP History - 179: ENIO reviewing OHIP summary.
RNC History - 433: ENIO prepares for Examination of Discovery.
RNC History - 434: Serino calls RNC and gives Serino a CIBC Visa number for a $1,000.00 payment. [Payment #6 = $1,000.00 = Total $5398.92]
ONT Courts - 01: The Superior Court of Justice for Ontario – Trial - Cooper vs. Tardis and TAC and RNC
RNC Business - 149 Small Claims Court for “Cooper Systems Development Corporation –and- Thomas Arthur Clark and Robert Neil Clark”.
RNC Business - 150 Small Claims Court Defense of Robert Neil Clark defendant in claim from Cooper Systems Development Corporation.
RNC Business - 151 The verdict from case against RNC and TAC will eventually be dismissed without cost.

[325] June 3 2002
ONT Courts - 02: Day 1 of the two day scheduled examination for discoveries. RNC vs. Equifax Canada Inc. (EFX) and Bank of Nova Scotia (BNS)
ZEP History - 180: ENIO mails correspondence to RNC regarding CIBC Visa $1,000.00 payment receipt.
Question ZEP - 219: Why did ENIO abandon RNC and the discoveries and not show up to represent RNC during the discoveries?
RNC History - 435: RNC realized that there were many unasked, therefore, unanswered questions about the involvement of EFX and BNS throughout the history during the discoveries proving that the discoveries were not serving their purpose in examining the truth of the history of fraud and theft leading to the credit errors.
RNC History - 436: During Lunch RNC asked Rombis to talk about the questioning but Rombis tells RNC that RNC can not sit with her.
RNC History - 437: RNC tries to tell Rombis about important questions that needed to be asked and that still were not asked by Rombis, but Rombis interrupts and tells RNC that she can not talk to RNC during breaks as per the Rules of Discoveries.
RNC History - 438: RNC was very confused why he can not talk to Rombis so RNC sits across the cafeteria and stares at her in anger.
RNC History - 439: RNC is angry with ENIO’s no show as RNC heard the severe lack of questions and undertakings asked by Rombis.
RNC History - 440: RNC’s Credit Report #11 from EFX contains 8 errors.
Errors by EFX - 129: Name Error - There is no “Jr” in RNC’s legal name. It is used by EFX without RNC’s consent!
Question EFX - 361: EFX won’t correct RNC’s name to its proper legal form. EFX continues defiance of revenge for lawsuit.
Errors by EFX - 130: Trade Line Error - There is two open CIBC Visa accounts when there should only be one.
RNC History - 441: The second CIBC Visa credit history is correct with a DLA of September 2000.
Errors by EFX - 131: Trade Line Error - BNS Visa comments should say ”Closed at consumer’s request”
RNC History - 442: RNC asked 3 times, BNS won’t do this out of spite – This is cause for damages as this is a simple task.
Errors by EFX - 132: Trade Line Error - Canadian Tire - Credit Advanced 5410 is wrong, it should only be $410.
RNC History - 443: That is a $5000 difference in the credit advance. Credit report dollar figures should be clearly accurate.
Errors by EFX - 133: Trade Line Error - CIBC Loan - Credit Advanced $14000 is wrong, it should be $14100.
Errors by EFX - 134: Trade Line Error - Canada Trust - Credit Advanced $10000 is wrong, it should be $10700.
Errors by EFX - 135: Trade Line Error - Brick Card - DLA 02/96
Question EFX - 362: Why did the Brick Account not purge in Feb 2002 according to EFX’s six year purge rule?
Errors by EFX - 136: Address Error – RNC has lived at 3 addresses after moving from 479 Dieppe in 1991 and before RNC moved from 166 Clements Road Ajax to Hewitt Crescent Ajax in Sept 1995. {inaccurate information}
RNC Claim - 372: Statutory Liability: A breach or violation of statute
RNC Claim - 373: Product Liability: Allows injured party financial compensation from the manufacturer or seller of a product.
RNC Claim - 374: Strict Liability: A false bad credit rating lowers credit score proving defendant’s object caused damage.
RNC Claim - 375: Professional Liability: A breach of duty owed in a professional capacity in connection with the firm’s business.
RNC Claim - 376: Vicarious Liability: (e/s) The defendant(s) are negligent for actions and/or inactions with my credit report and information.
RNC Claim - 377: Vicarious Liability: (e/s) The defendant(s) are negligent for false, inaccurate and missing information on my credit report.
RNC Claim - 378: Vicarious Liability: (r/c/t/o) The defendant(s) are negligent for their actions and/or inactions causing damage to or from others.
Claim vs EFX - 513 Negligence - - For telling untruths and evasion from truth forcing this matter to go to court for RNC to protect his innocence.
Claim vs EFX - 514 Negligent Infliction of Emotional Distress - - There is no reason why EFX can not correct my name – if there is – what is it?
Claim vs EFX - 515 Intentional Infliction of Emotional Distress - - EFX knows RNC wants his legal name back – EFX is unfoundedly malice.
Claim vs EFX - 516 Breach of Fiduciary Duty - - EFX has a duty to obtain, store and disclose the best possible most accurate credit information.
Claim vs EFX - 517 Breach of Contract - - A presumed agreement to disclose accurate non-false credit information about that person from EFX.
Claim vs EFX - 518 Breach of Trust - - Consumers have no choice but to put their faith and trust in corporations to correct their reporting errors.
Claim vs EFX - 519 Breach of Confidence - - Break-down of EFX credit reporting system shows the apparent weakness in the financial industry.
Claim vs EFX - 520 Breach of Promise - - EFX breached promise #10 (4th time) causing distress and panic over believed repeated credit report errors.
Claim vs EFX - 521 EFX is in Contravention of The Consumer Reporting Act Rule 8(1)(b), Rule 9(1), 13(1), 23(1), 23(2).
Claim vs EFX - 522 EFX is in Contravention of The Personal Information Protection Act Rule 9 (33) b.
Claim vs EFX - 523 EFX is in Contravention of The Personal Information Protection and Electronic Documents Act Rule 4.6.1, 4.6.3, 4.9.4, 4.9.5.
ZEP History - 181: ENIO mails correspondence to RNC regarding CIBC Visa $1,000.00 payment receipt. [Payment #5] [Total $4998.92]
Question ZEP - 220: Why did ENIO not show up to represent RNC during the discoveries?
ZEP History - 182: During Lunch RNC asked Pearl Rombis (ZEP) to talk. Pearl Rombis (ZEP) tells RNC that RNC can not sit with her.
ZEP History - 183: RNC tries to tell Pearl Rombis about questions to ask, but Pearl Rombis (ZEP) interrupts and tells RNC that she can not talk to me during breaks as per the Rules of Discoveries.
ZEP History - 184: RNC was very confused why RNC can not talk to her so RNC sits across the cafeteria.
ZEP History - 185: RNC felt that their was so many unanswered questions and that the discoveries were not serving their purpose in examining the truth of the credit history of errors and the involvement of EFX and BNS throughout.
ZEP History - 186: RNC is angry (#4) with ENIO’s no show as RNC heard the severe lack of questions and undertakings asked by our discoveries.

[326] June 4 2002
ONT Courts - 03: Day 2 of the two day schedule examination for discoveries.
ZEP History - 187: Rombis did not close off Sclisizzi BLG for BNS examination of discoveries correctly so that Sclisizzi of BLG for BNS scammed – cheated – deceived – RNC and the Superior Court into 5 extra days of study between his questioning.
RNC History - 444: RNC watched a terrible display of professionalism (both physically and verbally, especially by a lawyer) from Rombis.
RNC History - 445: Day 2 saw Rombis with her “sleepy school kid” posture slouched just inches over boardroom table during discovery.
RNC History - 446: RNC had barely any communication with Rombis and Rombis would not ask many important early history questions.
RNC History - 447: RNC feels that there should have many more undertakings requested by Rombis from EFX and BNS and witnesses.
RNC History - 448: RNC could not believe the examination for discoveries did not base mostly on the faults and errors of BNS and EFX.
RNC History - 449: RNC could not understand why there was this Rule of Discoveries of no communication between clients and counsel.
RNC History - 450: RNC was stuck with a discovery disaster, thanks to ENIO stating it was not necessary for him to be there!
RNC History - 451: RNC believes that without a (professional lead counsel) as acting counsel – RNC was set-up for disaster!
Question ZEP - 221: Why would ENIO say to RNC that “It is not necessary for me (ENIO) to attend discoveries” and not be lead counsel?
Question ZEP - 222: Why would ENIO abandon discoveries to a rookie associate against the Lead and Junior Counsels for EFX and BNS?
Question ZEP - 223: How could ENIO believe that abandoning discoveries as counsel would not hinder case with lack of professionalism?

[327] June 5 2002
ZEP History - 188: ENIO received and reviewed “Original Consent” from Buhler of BLG for BNS.
Question ZEP - 224: Why did RNC not receive a copy of this correspondence from Buhler of BLG for BNS?
Question ZEP - 225: What original consent is ENIO viewing and why?

[328] June 7 2002
ZEP History - 189: Serino phones RNC and demands more money for disbursement of the lawsuit.
RNC History - 452: RNC gives Serino a CIBC Visa number for a $1,000.00 payment.
ZEP History - 190: ENIO mails correspondence to RNC re: CIBC Visa payment receipt. [Payment #7 = $1,000.00 = Total $6398.92]

[329] June 10 2002
ONT Courts - 04: Day 3 of the two day schedule examination for discoveries.
Question BNS - 212: Martin Sclisizzi (BNS) completes his planned trickery and continues with his unwarranted examination after a 5 day review and study of the 2 days of discoveries
Question ZEP - 226: Why did I not get that opportunity to restudy questions and seek many more undertakings to my dozens of unanswered questions?
Question ZEP - 227: Why did my lead counsel not think it was necessary for ENIO to attend discoveries?

[330] June 12 2002
ONT Courts - 05: Deputy Judge Palmer dismissed case against RNC and TAC without cost. Tardis was not because of programmer excuses.
RNC History - 453: Judgment delivered for “Cooper Systems Development Corporation –and- Tardis Telecommunications and TAC and RNC”.
RNC History - 454: Deputy Judge Palmer rules against Tardis Communications for $7,562.62 and costs of $300.00 council fees and interest.
RNC History - 455: The verdict from case against TAC was dismissed without cost.
RNC History - 456: The verdict from case against RNC was dismissed without cost.
RNC History - 457: Mr. Cooper and Cooper Systems was ordered by the court to deliver a working program upon receipt of the payment.
RNC History - 458: Unfortunately, RNC’s continuing losses (time / thought / effort and some money) are gathering and adding to RNC’s total losses.
RNC History - 459: At this time, RNC still could not give a total on all losses directly or indirectly caused from case against EFX and BNS.

[331] June 27 2002
ZEP History - 191: ENIO mails Interim Statement of Account No. 14667/02 for $8,936.31. [April 19 2002 – June 27 2002] – 9838.05
ZEP History - 192: Rombis mails correspondence to RNC regarding the “Undertakings” and “Nuisance Value” settlement offer.
ZEP History - 193: ENIO faxes correspondence from Martin Buhler (BNS)
ZEP History - 194: List of 12 Undertakings – much less then RNC expected.
ZEP History - 195: ENIO faxes correspondence from Schwartz of CTN for EFX
ZEP History - 196: List of 10 Undertakings – much less then RNC expected.

[332] June 28 2002
ZEP History - 197: Rombis received and reviewed correspondence from Buhler of BLG for BNS re: “BNS Undertaking Refusals”.

[333] July 2 2002
ZEP History - 198: Rombis sends correspondence to RNC regarding June 28 2002 correspondence from Buhler of BLG for BNS.
ZEP History - 199: The End of Pearl Rombis LLB.
RNC History - 460: Unknown to RNC for months, this correspondence turns out to be RNC’s last communication to or from Rombis.
Question ZEP - 228: Why was Rombis dismissed from the case and fired from Zeppieri and Associates?
Question ZEP - 229: Why did ENIO not tell RNC that Rombis had and left Zeppieri and Associates months before RNC found out?

[334] August 12 2002
ZEP History - 200: ENIO and Theresa H_? (ZEP) misdirects and steals $26,000.00 from 2nd mortgage funds.
ZEP History - 201: After months of asking for help (since Mar 19 2002) from ENIO to find a second mortgage because of the previous unsuccessful attempt by Bob Pinkney (TD) to retain RNC’s credit report.
ZEP History - 202: ENIO sets up mortgage, then sends RNC and ROC to another lawyer for signing, and never sees the mortgage documents again.
ZEP History - 203: RNC and ROC was setup to have their money misappropriated without permission.
ZEP History - 204: $24,000 was assigned to pay off outstanding debts with $2,000 assigned for ENIO & Associates.
ZEP History - 205: RNC and ROC argued with Rose and Theresa (ZEP) until ENIO gave back $5k of the $24k mortgage.

[335] November 18 2002
ZEP History - 206: CIBC Mortgage Trust Corporation

[336] November 22 2002
ZEP History - 207: “Amended Statement of Claim”
ZEP History - 208: (March 7 2002 Amended Statement of Claim) stamped again on this date for reasons unknown to RNC.

[337] November 26 2002
ZEP History - 209: ENIO / Serino starts Statement Account No.15238/03 for $1713.90 [November 26th 2002 to January 28th 2003]
ZEP History - 210: ENIO sends correspondence to Schwartz of CTN for EFX.
Question ZEP - 230: Why did RNC not receive a copy of this correspondence to Schwartz of CTN for EFX?

[338] November 28 2002
ZEP History - 211: ENIO correspondence with associate.
Question ZEP - 231: Why correspondence among ENIO and Associates?
Question ZEP - 232: Who was next from the list of ENIO and Associates to take over RNC’s case?
Question ZEP - 233: Is this associate - Avril Hasselfeild from Zeppieri & Associates?
ZEP History - 212: ENIO sends correspondence to Schwartz of CTN for EFX.
Question ZEP - 234: Why did RNC not receive a copy of this correspondence?
ZEP History - 213: ENIO sends correspondence to Martin Buhler (BNS).
Question ZEP - 235: Why did RNC not receive a copy of this correspondence?

[339] December 4 2002
ZEP History - 214: ENIO prepares “Trial Record” material.
Question ZEP - 236: Is this Trial Record different then the Trial Binder “sent” December 12 2002?
ZEP History - 215: ENIO received and reviewed correspondence from Martin Buhler (BNS).
Question ZEP - 237: Why did RNC not receive a copy of this correspondence?
ZEP History - 216: ENIO received and reviewed “Amended Statement of Defense” correspondence from BNS.

[340] December 5 2002
Question BNS - 213: The BNS “Amended Statement of Defense” was re-stamped on this date for reasons unknown to RNC.

[341] December 6 2002
ZEP History - 217: ENIO received and reviewed correspondence from Martin Buhler (BNS).
Question ZEP - 238: Why did RNC not receive a copy of this correspondence?

[342] December 9 2002
ZEP History - 218: ENIO sends correspondence to Martin Sclisizzi (BNS).
Question ZEP - 239: Why did RNC not receive a copy of this correspondence?
ZEP History - 219: ENIO sends correspondence to Martin Buhler (BNS).
Question ZEP - 240: Why did RNC not receive a copy of this correspondence?
ZEP History - 220: ENIO received and reviewed correspondence from Martin Buhler (BNS).
Question ZEP - 241: Why did RNC not receive a copy of this correspondence?

[343] December 10 2002
ZEP History - 221: ENIO received and reviewed correspondence from Schwartz of CTN for EFX.
Question ZEP - 242: Why did RNC not receive a copy of this correspondence?

[344] December 12 2002
ZEP History - 222: Avril Hasselfeild (ZEP) mails correspondence to RNC re: Interim Statement of Account,
ZEP History - 223: ENIO asks RNC for copy of disks.
ZEP History - 224: RNC replies with a letter referring to the lack of co-operation from the RBC.
ZEP History - 225: RNC also mentions “diskcopy command” to copy the disk containing RNC earlier notes and letters.
ZEP History - 226: Avril Hasselfeild (ZEP) states “sent in Trial Binder” and ENIO is waiting for a “Trial Scheduling Date”. [Signature #1]
ZEP History - 227: ENIO received and reviewed “Amended Statement of Defence” from EFX.

[345] December 13 2002
ZEP History - 228: “Amended Statement of Defence” from EFX.
Question ZEP - 243: QUESTION: ARE PRE-TRIAL and TRIAL DATES KNOWN AT THIS TIME?
ZEP History - 229: ENIO is preparing “Trial Record”.
Question ZEP - 244: Is this Trial Record different then the Trial Binder “sent” December 12 2002?

[346] December 16 2002
ZEP History - 230: ENIO received and reviewed correspondence from Schwartz of CTN for EFX.
Question ZEP - 245: Why did RNC not receive a copy of this correspondence?
ZEP History - 231: ENIO received and reviewed “Amended Statement of Defence” from EFX.

[347] December 17 2002
ZEP History - 232: ENIO sending correspondence to Schwartz of CTN for EFX.
Question ZEP - 246: Why did RNC not receive a copy of this correspondence?
ZEP History - 233: ENIO sending more correspondence to Schwartz of CTN for EFX.
Question ZEP - 247: Why did RNC not receive a copy of this correspondence?