Otavnik vs Robertson

This court case is simple. Paintings’ by Norval Morrisseau approved by the Canadian Cultural Property Export Review Board (CCPERB) in 2004, yes 2004 where called “fakes” by Carmen Robertson in 2018. Since she has called them “fakes” the burden of proof lies with her.

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Reason for Courtcase. Carmen Robertson calls Norval Morrisseau paintings’ approved by the Canadian Cultural Property Expert Review Board “fakes”. Was given a chance to amend her “Expert Report” did refused to do so.

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Again, I helped facilitate a donation of Norval Morrisseau paintings’’ in 2004 to the Thunder Bay Art Gallery (TBAG) in 2004.  Again, they selected the paintings subject to this suit, they applied to the Canadian Cultural Property Export Review Board (CCPERB) which was of course approved. Carmen Robertson told the TBAG that the donation(s) were “fakes”. I pointed out to the TBAG that the source of my paintings were the same as their collection of Susan Ross paintings’’ etc. The bottom line is that I told the TBAG that they had to either support me (or Carmen Robertson) but they could not sit on the sidelines. They choose to do nothing so I sued them.





First of all I want to mention the Whent Case which was a case that was in the Tax Court of Canada
Don Robinson (of KRG) gave testimony in it but I will leave that to a separate video.
Don Robinson buys 28 paintings’ by Norval Morrisseau for $53,000 from Randy Potter (Kahn Auctions in Pickering) then moves to Cobourg and renames it Potter Auctions. Don Robinson then hires a PI to find the source of Potter’s Morrisseau paintings’ which turns out to be David Voss. Don Robinson tries to convince David Voss to sell to him and David Voss refuses to do so. Don Robinson thus cannot corner the market.
Don Robinson then enlists Marry Whyte of the National Post to write an article about his DR’s discovery of “fake” NM paintings being sold to KA. He never discloses to MW or the reader the fact that he bought 28 paintings for $53,000 thinks they are fake but never asks for his money back. (Don Robinson did ask for his money back on a $250 dollar painting from KA for another artist but not $53.000 for what he calls “fake” Morrisseau’s. Copy of the refunded cheque for $250.
After the article in the NP Don Robinsin sends out a letter to his clients’ informing them of his discovery of “fakes” being sold at KA and advises his clients’ to be very careful. (He of course did not disclose his own paintings that he bought at Kahn Auctions and resold  at his gallery KR).
At the same time Don Robinson is promoting Ritchie Sinclair as a Expert on Norval Morrisseau on his website KRG. Little does DR know that while he is promoting RS, RS on his website is calling paintings from one of KR publications’ NM Travels of the House of Invention” as “fakes’.  So RS is an expert on NM calling paintings in KR publication as “fakes” which believe it or not are hanging in the Smithsonian Museum in Washington DC. I am not making this up as it has been confirmed in court via the direct testimony of DR and SC.
I have included a Letter to the PM from Ritchie Sinclair and I will let the reader come to whatever conclusions he/she may think. Mind you SR is the person who DR and KRG claim as the Expert on NM.
Also, a brief mention on this page of a painting DR buys from Waddington’s which will be in a separate video.
 




David Voss came to Toronto in the late 1990’s and Maslak McLeod to try to see his NM paintings’
Joe told David that he couldn’t sell the Norval Morrisseau painting he had as fast as he wanted him too and he referred him to Randy Potter (of Kahn Auctions). David did business with Randy and Don Robinson sent a PI to Thunder Bay to locate Randy’s source. David sold paintings to Don Robinson but when DR wanted David to cut out Potter and just sell to him David said no (in an affidavit) and then Don Robinson started the whole “fake’ Norval Morrisseau narrative.
Go to the link that says “Proof of David Voss”
Letter dated Jan 2012 to Rolf Schneiders from Jonathan Sommer. Statement of facts that he dealt with David Voss for fifteen (15) years and David Voss provided him with paintings and he did business with him (David as previously mentioned supplied Kahn then Potter Auctions ran by Randy Potter. In the doc “There are no Fakes” RP discussed his relationship with DV.
Now the provenance given to Kevin Hearn it lists Rolf Schnediers and Robert Voss who is of course David Voss as in his real name Robert David Voss, some people call him Robert some people call him David. Expert Report by Carmen Robertson, RS tells her he knows of David Voss but not Robert Voss but heard of a Voss family in the TB area. Is anybody this stupid I mean really.
My legal name the name of my Birth Certificate is Joseph Otavnik but people call me Joe. So if someone asks do you know of a Joseph O would people say No but I heard of an Otavnik family name in Oshawa. I mean really.
 
 





First of all I want to mention the Whent Case which was a case that was in the Tax Court of Canada
DR (Don Robinson of Kinsman Robinson Galleries) gave testimony in it but I will leave that to a separate video.
DR buys 28 paintings’ by Norval Morrisseau for $53,000 from Randy Potter (Kahn Auctions in Pickering) then moves to Cobourg and renames it Potter Auctions. DR then hires a PI to find the source of Potter’s Morrisseau paintings’ which turns out to be David Voss. DR tries to convince DV to sell to him and DV refuses to do so. DR thus cannot corner the market.
DR then enlists Marry Whyte of the National Post to write an article about his DR’s discovery of “fake” NM paintings being sold to KA. He never discloses to MW or the reader the fact that he bought 28 paintings for $53,000 thinks they are fake but never asks for his money back. (DR did ask for his money back on a $250 dollar painting from KA for another artist but not $53.000 for what he calls “fake” Morrisseau’s. Copy of the refunded cheque for $250.
After the article in the NP Dr sends out a letter to his clients’ informing them of his discovery of “fakes” being sold at KA and advises his clients’ to be very careful. (He of course did not disclose his own paintings that he bought at Kahn Auctions and resold  at his gallery KR).
At the same time DR is promoting RS as a Expert on NM on his website KRG. Little does DR know that while he is promoting RS, RS on his website is calling paintings from one of KR publications’ NM Travels of the House of Invention” as “fakes’.  So RS is an expert on NM calling paintings in KR publication as “fakes” which believe it or not are hanging in the Smithsonian Museum in Washington DC. I am not making this up as it has been confirmed in court via the direct testimony of DR and SC.
I have included a Letter to the PM from RS and I will let the reader come to whatever conclusions he/she may think. Mind you SR is the person who DR and KRG claim as the Expert on NM.
Also, a brief mention on this page of a painting DR buys from Waddington’s which will be in a separate video.
 

Proof of David Voss pdf

Enclosed please find a copy of the letter addressed to Mr. Rolf Schneider from Jonathan Sommer (i.e. lawyer for Kevin Hearn) dated Jan 2012 and the statement of facts signed by Mr. Schneider in Feb2012. Furthermore, please find a portion of the “Expert Report” by Carmen Robertson which was used at trial in  2017. So, Rolf Schneider admits to knowing a David Voss for fifteen (15) years in 2012 but when is asked by Carmen Robertson after that he has never met a Robert Voss –but has heard of the Voss family. In reality this is the same person whose name is Robert David Voss, some people call him Robert and some people call him David. My legal name is Joseph but people call me Joe. If anybody who is reading this thinks that Robert Voss and David Voss are two (2) different people then you are an idiot. Moreover, the defense is aware of an affidavit signed by Robert David Voss where he acknowledges that he has done business with both Mr. Rolf Schneider and Don Robinson of Kinsman Robinson.

So why all this deception? The provenance given to Kevin Hearn shows the names of Mr. Rolf Schneider and Robert Voss which is a big problem for Sommer and Hearn and the defendant (Carmen Robertson). The question is what has the lawyer (Sommer) disclosed to his client (Kevin Hearn) and Carmen Robertson.  Is Carmen Robertson aware of this letter? If so, is she really stupid enough to suggest in her “Expert Report” that Robert Voss does not or ever existed?  You would think that at least Rolf Schneider would say I don’t know of Robert Voss but I dealt with David Voss? Instead, Carmen Robertson claims that Rolf Schneider told her the he heard of a family named “Voss” who settled in the area. What about Don Robinson?,  the defense knows that Robert David Voss knew and dealt with Don Robinson so Robinson knows that Robert David Voss does exist.

It is clear that Sommer knew that Robert David Voss did/does exist and Robert David Voss dealt with Rolf Schneider and he didn’t disclose that to his client ( Kevin Hearn) and Carmen Robertson.

As noted blow please the find the Government funding for the defendant. The defendant in this case is being funded by the Government of Canada, yet has called paintings’ by Norval Morrisseau “fakes” even after they were deemed authentic by the Canadian Cultural Property Export Review Board hereinto referred to as the CCPERB.

This is just background Information for now as I will post the Entire Plaintiff’s Claim and Defense shortly.

Background

Plaintiff and his family donated four (4) works of art by Norval Morrisseau to the Thunder Bay Art Gallery (in 2004) under the strict rules of the Canadian Cultural Properties Export and Import Act.  The Thunder Bay Art Gallery (TBAG) which is a Class “A” Gallery duly accepted, verified, vetted and accepted the artwork for review and final application to the Canadian Cultural Property Export Review Board (CCPERB). Since the title of the painting would transfer to the Thunder Bay Art Gallery the Gallery (after approval by the CCPERB) the TBAG was the applicant to the CCPERB. The CCPERB  then accepted, verified, vetted the application, verified the authenticity of the paintings’, approved their Fair Market Value, outstanding significance and national importance of the paintings’ and certified/approved the application submitted by the TBAG. The plaintiff and his family then received a Cultural Property Income Tax Certificate issued through Revenue Canada after of course approval by the CCPERB.

Despite the approval of the TBAG, CCPREB, Revenue Canada etc , in September 2017, the Plaintiff became aware of a “Expert Report” by the defendant that was to be used in court case in which the defendant clearly , identified and called “fakes” or “attributed to Norval Morrisseau” the same paintings’ as above and approved by the parties mentioned as above. The defendant included pictures of the paintings’ the plaintiffs’ family donated and description of them can clearly be considered defamatory under the common sense usage of the terms she described them as.

Again, the paintings’ in question and subject of this suit identified as “fakes” by the defendant have been vetted by over 20 professional independent experts, the staff of the , TBAG , CCPERB Board and the full ten (10) Member Board of the CCPERB. The Canadian Government then issued a Cultural Property Tax Certificate for the fair market value of these paintings’.

At this point you have to ask yourself, What is going on? The gallery who accepted, verified and authenticated the donation in question (in 2004) no longer stands by it? Why have they thrown the main curator (who I will not name for the moment) who approved it at that the time under the bus? The paintings’ in question were again approved by the Canadian Cultural Property Export Review Board (CCPERB) staff and then entire Board then Revenue Canada etc? Moreover, the defendant will offer no witness (or experts etc) to back her claims nor is she going to testify according to her lawyer. (The CCPERB) will testify and re-affirm the original donation-but again nobody will testify for the defendant’s position including herself?

                                     Pustina V R, 96 D.T.C. 1594, [1996] 3 C.T.C. 2542

Gary Lamont Donations in the Pustina, Whent et all vs. Her Majesty the Queen (Tax Court). (Issue at trial is valuation of the block donation for tax purposes and not the authenticity of the artwork para. 7). The paintings are/were are signed on the back in black dry ink and approved by the Canadian Cultural Property Export Review Board (hereinto referred to the CCPERB). The court transcript clearly identifies Mr. Gary Lamont (at para 26 and para 27) as the source of some of the paintings’ that were donated to the various galleries and institutions which were 100% certified as 100% authentic.

As per Page 16 and page 23 some of the paintings’ went to the following Institutions

I cannot determine which of the paintings’ donated to the above came directly from Gary Lamont but some obviously did as they were part of the total donation(s) as per the above.

Don Robinson testifies as an “Expert Witness” but court finds Joe McLeod more Credible as per paragraph  84 . Moreover, at para 101 the court clearly states that “ I have stated why I place little reliance on Mr. Robinson’s appraised value of $1,105,000.

Don Robinson and the start of the Narrative of Fake Norval Morrisseau paintings’

National Post Article

National Post article and “fake” narrative started by Don Robinson. Robinson is calling paintings’ from Kahn Auctions “fakes”. He fails to disclose to the writer (and his clients’) that he bought 28 paintings’ for $53,000 but didn’t ask for his money back even after calling them “fakes”. (He does however, ask for a refund for a $250 for a painting he thinks is “fake” also bought as Kahn Auctions). See enclosed affidavits’ and sales receipts. Don Robinson was forced in trial to admit to these facts.

Please now refer to Don Robinson’s  letter to his clients’ informing them of his discovery of these “fake” Norval Morrisseau paintings’ he discovered were being sold at Kahn Auction. (He conveniently forgets to tell clients’ he bought from the same place he called fakes and then re-sold them in his gallery –all from Kahn Auctions. I will present all the sales receipts in a pdf file as soon as I learn how to do it.

Ritchie Sinclair calling paintings’ in Don Robinson’s (Kinsman Robinson) “fakes” from his book Norval Morrisseau: Travels to the House of Invention”. Only problem is that they are hanging in the Smithsonian Museum in Washington, DC. (Yes, folks that Smithsonian). Again, I will present it in a pdf format as soon as I learn how.

When asked in court about this Ritchie replied “They (the Smithsonian) should have asked me as I am the Expert”.

Ritchie Sinclair letter to the Prime Minister.

DON Robertson the RAT Below please find correspondence between Don Robinson and the RCMP. You can clearly see Robertson asking the RCMP to check on his competitors. Please notice how he asks them to check and see if they are signed on the back in dry black ink as he is pressing the narrative that those signed in the back as such are fake. Please also note how Robinson uses an alias for email address.

We don’t needing no stinking Provenance!

Robinson purchase at Waddington’s but presents it as being acquired directly from the artist when he resells it in his gallery.

I will be posting the actual plaintiff’s claim and defence soon and also be adding contact information.

____________________________________________________________________________________________________________________

Plaintiff’s Claim

The Plaintiff seeks damages for Defamation under commons law and Slander of Title under the Ontario Libel and Slander Act R.S.O. 1990 c.12.

                                                                                Background

Plaintiff and has family donated four (4) works of art by Norval Morrisseau to the Thunder Bay Art Gallery (in 2004) under the strict rules of the Canadian Cultural Properties Export and Import Act.  The Thunder Bay Art Gallery (TBAG) which is a Class “A” Gallery duly accepted, verified, vetted and accepted the artwork for review and final application to the Canadian Cultural Property Export Review Board (CCPERB). Since the title of the painting would transfer to the Thunder Bay Art Gallery the Gallery (after approval by the CCPERB) the TBAG was the applicant to the CCPERB. The CCPERB  then accepted, verified, vetted the application, verified the authenticity of the paintings’, approved their Fair Market Value, outstanding significance and national importance of the paintings’ and certified/approved the application submitted by the TBAG. The plaintiff and his family then received a Cultural Property Income Tax Certificate issued through Revenue Canada after of course approval by the CCPERB.

Despite the approval of the TBAG, CCPREB, Revenue Canada etc , in September 2017, the Plaintiff became aware of a “Expert Report” by the defendant that was to be used in court case in which the defendant clearly , identified and called “fakes” or “attributed to Norval Morrisseau” the same paintings’ as above and approved by the parties mentioned as above. The defendant included pictures of the paintings’ the plaintiffs’ family donated and description of them can clearly be considered defamatory under the common sense usage of the terms she described them as.

Again, the paintings’ in question and subject of this suit identified as “fakes” by the defendant have been vetted by over 20 professional independent experts, the staff of the , TBAG , CCPERB Board and the full ten (10) Member Board of the CCPERB. The Canadian Government then issued a Cultural Property Tax Certificate for the fair market value of these paintings’.

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                                FACTS

1) The defendant has identified the paintings’ as “fakes” or in her words ” Attributed to Norval Morriseau ” which be the normal understanding and use of the terms in the art world/business. The defendant clearly knew or should have known what she was implying by her words , identification and inclusion of these paintings’ in her Report as “fakes”.

2) In law since she has Slandered the Title of these paintings’ she must prove her conclusions and the burden of proof is on her. She has also defamed me and my family by calling them “fakes”. The implication of my family donating “fake” works of art either suggest we are idiots who don’t know what a real Norval Morrisseau is or we have deliberately  tried to mislead and defraud the Government of Canada.  Again, it is not on the Plaintiffs’ burden to proof the paintings’ are authentic but will.

3) The defendant simply cannot provide evidence of justification , fair comment, qualified privilege, truth or truth that it is the public interest. I have contacted her employer (The University of Regina) and they assure me that the defendant has prepared her report as a private citizen.

4) As per Exhibit “A” please find a copy of a of the application prepared by the Thunder Bay Art Gallery and the accompanying report. In it the Gallery highlights the significance of the donated paintings’, their authenticity, historical significance etc. The paintings’ are clearly labelled, named with accompanying pictures, titles  and other description(s). I will further note that the application was signed off by the register, Head curator and Galley director, then of course further vetted by the entire Board of Directors’ of the Gallery.

                                                                                                 -3-

5) I do not have at this time a copy of the decision by the CCPREB since only the receiving Institution (The TBAG ) does as the Gallery is the actual applicant. The plaintiff never asked for a copy from the TBAG since the CCPREB signed off on it and the plaintiff saw no need for it. The plaintiff has spoken to and communicated with the CCPREB and have been assured they will provide whatever document I require.  

6) Same is true for the Cultural Property Income Tax Certificate. Since the application was approved over thirteen (13) years ago the plaintiff has had difficulty finding it but can and will since it was issued. The point is that the CCPREB or Revenue Canada will have a copy somewhere.

7) As per Exhibit “B” please find an “Expert Report” prepared by the defendant in CV-12-0455650 were on pages 4,5,11,12,13,14,15,16,20,21,22,57,58,59 the identification and labelling as “fakes” the paintings’ subject to this lawsuit. There can be no doubt that the paintings which are the subject of this suit were in fact donated by the plaintiff. (Not in the filings in order to not exceed the 20MB limit, however, since it is your Report who should know the contents).

8) The defendants’ “Expert Report” is nothing but her opinion and backed by no forensic evidence. The Plaintiff on the other hand can show the various reports from several different independent forensic handwriting experts all of which can conform the signature on the paintings’  in black dry paint as those of the artist-Norval Morrisseau. Plaintiff can and will provide reports on the spectrum analysis of the paint on the paintings’ as being from the 1970’s etc due to the lead content and other chemicals used at that time in paint.  The defendant cannot provide anything but her half baked opinions which have been disproven in the courts.

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9) The main conclusion of the defendants” “Expert Report” and proof of these paintings’ as “fakes” are based on the premises that the artist-Norval Morrisseu did not sign the back of his paintings’ in black dry paint in the 1970’s. This is the distinguishing feature of these “fakes” and other such paintings with this specific feature as claimed by the defendant.

10) The defendants claims of “fakes” based on this fact clearly show the carelessness, recklessness, and lack of due diligence on her part. The defendant could have easily discovered what the courts, experts , auction house and worldwide internationally respected Galleries have concluded and communicated to the public at large. She could have done all this at her computer.

11) The defendant could have easily researched the judges’ decision in Margaret Hatfield v Donna Child in SC 09-87264 as per Exhibit “C” which the plaintiff easily found on the internet vs. a simple search on the Google search engine. In it the Judge clearly states “the court finds overwhelming evidence that Norval Morrissseu signed paintings in Black Dry Paint”.

12. The defendant could have simply searched the auctions results of any major auction house. If she had done so she would have seen many paintings of the same type, style, time period which were sold at auction were signed in Black Dry paint. She would have seen the front and back of the paintings and the detailed descriptions which would, have clearly highlighted the signature on the back of the paintings’ signed in black dry paint and even described as such in the auction information section. This, in addition to the TBAG, CCRERB, and the courts you can add major National and International auction houses to the list of people who seemingly don’t know what constitutes a “fake” Norval Morrisseu painting is except of course the defendant.

                                                                                                 -5-

13) The plaintiff successfully sued Gabe Vadas who was Norval Morriseau’s manager over allegations that he tried to sell a “fake” Norval Morrisseau at Heffel Auction house in 2008 as per Exhibit “D”. Mr. Gabe Vadas contended that since the painting was signed in Black Dry Paint it was a “fake”. The paintings is/was from the same source as the four (4) which are subject to this suit. Heffel pulled the piece from the auction. I sued for loss of potential sale. I had a forensic hand writing analysis preformed and other forensic tests on the painting. I ask the court to review the analysis and results. I then offered up the paintings’ for inspection for him (Gabe Vadas) for his experts to examine. He declined and just paid out the full amount of the claim with costs. I leave it to this court to draw its own conclusions.

14) The defendant should have know that the paintings’ with the same feature she claims to be distinguishing feature of a “fake”  Norval Morrisseasu are even hanging in the National Gallery of Canada and the Smithsonian Institution in Washington . With the Smithsonian you can access the permanent collection and again you will see a picture of the front and back with the signature labelled as being in Black Dry Paint.

15)  Even in the case were her Report is being used in, one of the witnesses (Richie Sinclair) has also claim “fakes’ that are in the Smithsonian Institution which were in a publication ” Travels to the House of Invention” produced by another witness (Don Robinson of Kinsman Robinson) for the same case for the same plaintiff. I am not making this up. This is also available via the public record and in court transcripts. Again, and to be clear one of the witnesses for the plaintiff  in CV-12-455650 has claimed the other witness published in a book pictures of paintings’ in the Smithsonian he considers to be “fakes”.  This is not my opinion but in court transcripts, filings’ and actual Exhibits.. Again, these are all part of the public record and could have been checked by the defendant again through a quick and easy Internet search.

                                                                                                 -6-

16) Don Robinson (of Kinsman  Robinson) claimed that Kahn Auctions was/were selling “fake” Morriseau paintings’ because again they were signed in Black Dry Ink. He changed his tune, (in court again) once confronted with the sales receipts of Norval Morrisseau paintings’ he bought at Kahn Auction who you guessed it were signed in the back in Black Dry Ink. Again, this was in court , part of the public record and should have been know by the defendant. I have a copy of the sales receipts and transcripts’ which I will  include in an additional filing as I am rushing to complete the Statement of Claim but will provide them within (one week) of this filing.

17)  Don Robinson as per above and per Exhibit  “E” you can see the results for Levis Auction House showing the Provenance from Kinsman Robinson which is identified as being signed, tilted and dated verso. This means it was signed in Black Dry Paint on the back. After this was pointed out to Mr Robinson (in court) he suffered from memory loss. Also as per Exhibit  “F” you can see an appraisal from Kinsman Robinson of a client who purchased a painting from Kahn Auctions which again was signed and dated on the back in Black Dry Ink (faded). Again, the same people who claimed the same features as being “fakes” of course which again in court they just couldn’t remember.

18) As per the defendants’ ” Expert Report “in CV -12-455650 the defendant highlights the importance of a Provenance of a painting (Spirit Energy of Mother Earth) and concludes that the provenance given in this case was not credible. (page 15). Despite this conclusion for that paintings’ the defendant had no clue of the provenance of the four (4) paintings ‘ subject to this suit. I spoke Sharon Godwin who is the current Director of the Thunder Bay Art Gallery now and when I donated the four (4) paintings’ who knows me well. She has confirmed to me the defendant has no idea of who donated the paintings’ nor does she have any clue of the Provenance of these paintings.

                                                                                                 -7-

19) As far as provenance goes please refer to Exhibit  “G” from the Kinsman Robinson website which highlights a painting for sale with the clear description of being “acquired directly from the artist”. However, you will note form Exhibit  that Kinsman Robinson actually bought the painting  at Waddington’s off the wall auction. So much for provenance.

20) The plaintiff can point to and highlight several different independent forensic examiners who all verify that Norval Morrisseau painted the back of his paintings’ in Black Dry Paint and verified the signature.  Please refer and find a report by Mr. Brian Lindblom as per in Exhibit “D”. Also, please find the findings’ of Judge J. Martial with respect to the report prepared Dr. Atual K Singla  as per Exhibit “C”. Also please find as per Exhibit ” H”  a  Forensic Report prepared by Mr. Kenneth Davies for the painting subject to the lawsuit in CV-12-455650.

21) Plaintiff is also preparing a Motion for intervener Status in CV-12-455650. I have enclosed a copy of that endorsement as per Exhibit “I”.

22) Experts who are considered experts by the Tax Court of Canada who testified in Whent, Pustina et al v R, 96 D.T.C. 1597, [1996] 3 C.T.C. 2542 also reviewed the paintings in question and deemed them to be authentic.

23) The defendants use of her “Morellian Analysis” to again suggest a “fake” was already used in another court case and dismissed. The judge dismissed the analysis which is the same one used in this case by the defendant. However, since each case in court is judged on its own merits the defendant will have her chance to do so in court.

                                                                                                 -8-

24) Also please find as per Exhibit “J” A copy of a reason court decision involving Ritchie Sinclair or a.k.a “The Star Dreamer”. It’s quite the read and he is involved with Jonathan J. Sommer right through all their lost and abandoned cases with respect to Norval Morrisseau.

19) The plaintiff concedes that if the whole art world is wrong including the National Gallery of Canada, the Smithsonian, the courts, independent forensic experts the CCPREB, Revenue Canada , Tax Court of Canada etc and the defendant is right then I (the plaintiff will lose).  

All eight (8) pages of which is respectfully submitted

Defence