On Mon, 08 Apr 2002 15:19:16 GMT, hkhenson@cogeco.ca (Keith Henson) wrote:

Here is the meat of what we put in the complaint. Gregg's differs from mine in that he was only assaulted and not arrested. Today's mail has their response. Will scan and post.

Keith Henson

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Assault, using excessive force, libel, pain and suffering, intentional infliction of emotional distress, false imprisonment.

The Plaintiff claim is for damages of $10,000 against the Defendant Police Officers and the Defendant Police Services Boards for false and unlawful arrest and imprisonment. The Plaintiff claim is also for damages under Section 24 (1) of the Charter of Rights and Freedoms, for arbitrary arrest, contrary to Section 9 thereof and for being deprived of his rights to liberty and security contrary to Section 7 thereof.

The Plaintiff claim is also for damages as above for assault and abuse of process by arresting the Plaintiff at gunpoint with excessive force, violence, and numbers by means of armed members of Halton Tactical Response Team (TRU) under the direction of the Metro Toronto Police Officers.

The Defendants recklessly endangered the lives and safety of the Plaintiff by surrounding the Plaintiff at the Oakville Place Mall on Leighland Street in Oakville on May 28, 2001 at 2:35 P.M. with guns and semi-automatic weapons pointed at the Plaintiff without identifying themselves as Police Officers. In doing so they terrorized the Plaintiff. Such extreme force and numbers was unnecessary, unreasonable, and arbitrary in the execution of the Immigration Warrant for Inquiry into a non-criminal matter.

The Defendants recklessly obtained and executed the warrant without proper enquiry and placed unreasonable reliance upon unsubstantiated allegations and information easily discernable as biased and erroneous which was maliciously supplied by a notorious convicted felon: the so called 'Church' of Scientology.

Some of the Defendants libelled the Plaintiff in the press and to an Immigration case officer.