JPRC Panel Refuses to Hear J.P. Massiah's Motions

March 6, 2017

Madam Registrar:

We hereby seek the panel's leave to bring the
attached motion seeking a re-opening of the
2012 Panel's findings on liability and penalty
pursuant to the Procedures Document and the
established jurisprudence....

We trust that this is satisfactory.

E.J. Guiste and J. House
Co-counsel for the Applicant


March 8th, 2017

Justices of the Peace Review Council
1 Queen Street East, Suite 2310
Toronto, Ontario, M5C 2W5

Attention:  Ms. M. King, Registrar and Counsel

Dear Ms. King:

RE: MASSIAH - COMPENSATION - REHARING - MOTION FOR DISCLOSURE OF
APPOINTMENT LETTER RE HON. JUSTICE LIVINGSTONE AND H.W.
CUTHBERTSON BY CHIEF JUSTICE

Pursuant to the Procedures Document we seek the panel's leave to bring the
within motion for adjudication by the panel.

Disclosure:

On March 8th, 2017 the Registrar advised that Justice Livingstone and
H.W. Cuthbertson were appointed temporary members of the JPRC by the
Chief Justice effective May 28, 2013.

The letter and or all documents making this appointment are relevant in this
proceedings as there is an issue about the composition of the hearing panel..
H.W. Massiah maintains that the hearing panel was not properly constituted.


March 8th, 2017

JUSTICES OF THE PEACE REVIEW COUNCIL
1 Queen Street East, Suite 2310
Toronto, Ontario, M5C 2W5

Attention:  Ms. M. King, Registrar and Counsel:

Dear Ms. King:

RE: MASSIAH - COMPENSATION - REHEARING - REASONABLE
APPREHENSION OF BIAS MOTION PER PROCEDURES DOCUMENT

Pursuant to the Procedures Document we bring the within motion for
adjudication by the panel.


Procedures Document

18(1)   Either party to the hearing may, by motion, not later than 10 calendar
days before a set-date, bring any procedural or other matters to the hearing panel
as are required to be determined prior to scheduling the hearing of the complaint

18(2)   Either Party to the hearing may, by motion, not later than 10 calendar days
before the commencement of the date set for the hearing, bring any procedural or
other matters to the hearing panel as are required to be determined prior to the
hearing of the complaint.

18(3)   Without limiting the generality of the foregoing, a motion may be made
for any of the following purposes:

b.   resolving any issues with respect to any reasonable apprehension of bias or
institutional bias on the part of the panel;

c.   objecting to the sufficiency of disclosure by presenting counsel;

d.   determining any point of law for the purposes of expediting the hearing;

19.   The hearing panel shall, as soon as is reasonably possible, appoint a time
and a place for the hearing of submissions by both sides on any motion brought
pursuant to section 18, and shall, as soon as is reasonably possible, render a 
decision thereon.


Decision dated March 30, 2017
on Motions

23)    a.   .....we decline to further consider Motion 1;

          b.   ....we decline to further consider Motion 2;

          c.   To avoid an abuse of process, Mr. Massiah is to file no more motions without
                leave from this Hearing Panel.

           d.   We will not consider the Notice of Motion of 6 March 2017 indicating an
                  intention to file a motion seeking remedies beyond our jurisdiction.


NOTE:  This information is being published as a public service.  The Hearing Panel has
ordered that the re-hearing ordered by the Divisional Court will not involve a traditional
public hearing. The removal of a judicial officer in our system is an issue of public
importance.  The manner in which the proceedings are conducted are clearly an issue of
public importance.  Justice must be seen to be done.  It is in this spirit and in this spirit
only that this publication is made.

Note: Some text is in bold for emphasis.