Court File No

Court File No:

SUPREME COURT OF PRINCE EDWARD ISLAND

(Trial Division)

BETWEEN:

BLAIR E. ROSS

APPLICANT

AND:

HER MAJESTY THE QUEEN

RESPONDENT

NOTICE OF APPLICATION

TO THE RESPONDENT:

A LEGAL PROCEEDING HAS BEEN COMMENCED by the Applicant, the

claim made by the Applicant appears on the following pages.

THIS APPLICATION will come on for a hearing on the _______ day of August,

2003, at _______ in the _____ noon, at the Sir Henry Davies Law Courts Building, 42 Water St.,

Charlottetown, PEI.

IF YOU WISH TO OPPOSE THIS APPLICATION, you or a Prince Edward

Island lawyer acting for you must forthwith prepare a Notice of Appearance in Form 38A

prescribed by the Rules of Civil Procedure, serve it on the Applicant and and file it, with proof

of service, in this Court Office, and you or your lawyer must appear at the hearing.

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IF YOU WISH TO PRESENT AFFIDAVIT OR OTHER DOCUMENTARY

EVIDENCE TO THE COURT OR TO EXAMINE OR CROSS-EXAMINE WITNESSES

ON THE APPLICATION, you or your lawyer must, in addition to serving your Notice of

Appearance, serve a copy of the evidence on the Applicant and file it, with proof of service, in

the Court Office where the application is to be heard as soon as possible, but no later than 2:00

in the afternoon on the day before the hearing.

IF YOU FAIL TO APPEAR AT THE HEARING, JUDGMENT MAY BE GIVEN

IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU.

Dated this _____ day of August, 2003

______________________

REGISTRAR

Sir Henry Davies Law Courts Building

42 Water St.

Charlottetown, P.E.I.

C1A 7N8

TO: JOHN MACMILLAN

CROWN ATTORNEY

197 Richmond St.

Charlottetown, PEI

C1A 1J3

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The applicant makes application for:

1) A Review of an Order, Pursuant to Section 520 of the Criminal Code of Canada and amendments thereto;

1) An Order to vacate an Order made by Charles Thompson, Prothonotary, during a Show Cause Hearing on the 19^th day of August, 2003, to detain the applicant in custody pursuant to Section 515.(10)(b);

1) An Order releasing the applicant pending his trial upon reasonable conditions pursuant to Section 515.(4) and (4.1); and

1) The applicant’s presence at the hearing as he is acting on his own behalf.

The grounds for the application are:

1) The Crown is going by way of summary conviction for the alleged Criminal Code of Canada charges laid against the applicant;

1) The applicant’s only criminal record is 1978 and 1985 with none being assault;

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1) The applicant ought to be released pending his trial due to the fact that his detention is

unwarranted pursuant to the statutory criteria set out in Section 515.(10)(b), that the prosecutor show cause why the accused should not be released on a form of release representing the least interference with the accused’s liberty or to justify the accused’s detention pending trial, in particular (b) must be justified on the basis that it is necessary for the protection or safety of the public, namely that there is a substantial likelihood that the applicant, if released, will interfere with the administration of justice or commit further crimes;

1) The victim herself requested a peace bond or a restraining order against the applicant, as she needed some space;

1) The applicant is the husband of the victim and they have been in each others lives without incident, until these alleged events transpired;

1) The evidence before the court is circumstantial, hearsay and in some cases conspiratorial against the applicant;

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1) The applicant is acting on his own behalf and allowances must be made in order for the applicant to prepare for his defence, as is his Charter Right of Life, Liberty and Security of Person, as the principles of fundamental justice contemplate an accusatorial and adversarial system of criminal justice which is founded on respect for the autonomy and dignity of the person. These principles require that an accused, who is fit to stand trial, have the right to control his own defence. Any limit on this right must be the least intrusive and ensure that there is no discrimination;

1) The applicant has specific injury to his person when incarcerated which infringes on his Charter Right of Life, Liberty and Security of Person;

1) The applicant’s Show Cause hearing denied and infringed his Charter Right on arrest or detention to be informed promptly of the reasons therefor and his Charter Right of Life, Liberty and Security of Person;

1) The applicant’s Show Cause hearing was malicious prosecution and infringed and denied the applicant’s Charter Right of Equality before and under law and equal protection and benefit of law;

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1) The applicant has apprehension that the Prothonotary, Charles Thompson has bias and infringed and denied his Charter Right not to be arbitrarily imprisoned, to be presumed innocent until proven guilty according to law in a fair and public hearing by an independent and impartial tribunal, not to be denied reasonable bail without just cause and to be treated fairly and just without discrimination. The applicant has abided by undertakings with reasonable conditions in the past.

2) There are numerous discrepancies between the events spoken of by the victim and fact that infringe and deny the applicant’s Charter Right for Life, Liberty and Security of Person.

The following documentary evidence will be used at the hearing of the application:

1) Section 520.(7) of the Criminal Code of Canada and amendments thereto

2) Disclosure from the prosecution, 41 pages

3) Affidavit of the applicant which includes Exhibits A to O

4) No transcript = R. v. Carrier, supra.

In order to encourage expeditious disposition of bail matters

1) Nature of review = “A review” of the justice’s order gives the judge the power to substitute their own discretion. The new bail sections should be liberally interpreted in favour of the accused with less emphasis on the nature of the offence: R. v. Thompson (1972), 7 C.C.C. (2d) 70, 18 C.R.N.S. 102 (B.C.S.C.)

_________________ Blair E. Ross

c/o Provincial Correctional

Centre, Sleepy Hollow

Court File No:

SUPREME COURT OF PRINCE EDWARD ISLAND

(Trial Division)

BETWEEN:

BLAIR E. ROSS

APPLICANT

AND:

HER MAJESTY THE QUEEN

RESPONDENT

AFFIRMATION OF APPLICANT

I, BLAIR EARL ROSS, the Applicant, residing in Morell, County Kings, in the Province of Prince Edward Island, AFFIRM AND SAY AS FOLLOWS:

1. I am the person mentioned in the Information (no case number) signed by S. Clory, Justice of the Peace, and as such, have personal knowledge of the facts herein deposed, except where otherwise stated to be based on information and belief.

1. According to Prosecutor’s Information Sheet, dated August 19, 2003 on August 16, 2003, Ann Marie Ross attended the Souris RCMP office to request a restraining order.

1. The statement of Jackie Ann MacKay, dated August 18, 2003, 15:30 hrs states: Ann Marie has worked there close to 14 years, she is like a daughter to me a very fine little girl.

1. Ann Marie and I have known each other for 14 years, we have been married for four years. Ann Marie has a mother.

1. If Ann Marie is like a daughter to Jackie MacKay, I believe that Ann Marie would be receiving a proper wage for her years of employment, instead Jackie offers Ann Marie, certain financial help, however, this help, can keep Ann Marie in her employment.

1. The statement of Jackie MacKay continues: Her husband is Blair Ross he used to drive her to work here all the time after he got hurt ______ would go over to Debbie Hawkes’s place I think that is when all the trouble started.

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1. Ann Marie and I share the vehicle, I purchased, for transportation purposes. (Exhibit A = proof of purchase)

1. Deborah and I first met when she was on a hunger strike and staying in her car at Province House, later Deborah supported my 64 day hunger strike at the Cenotaph and subsequent unlawful arrest by a brigade of City of Charlottetown Police Constables, when I was denied proper medical attention and was unlawfully incarcerated while the two other women arrested with me were released. (Exhibit B = Guardian article)

1. Hawkes and myself are founding a new political party on PEI called the Fundamental Rights Party and with also dealing with civil and criminal cases on a regular basis, it is very convenient that Deborah Hawkes lives next door to where Ann Marie works and Deborah rents her home from Jackie MacKay.

1. On days where Ann Marie was working a 7am to 3pm shift, after Deborah’s children went to school at 8:30am, Deborah and myself would also be working.

1. Some people have a difficult time in understanding the political mentor relationship and friendship that Deborah and I share.

1. Jackie MacKay could be one of these people, could she have been asking Ann Marie on a regular basis while Ann Marie was at work, what was Deborah and I doing all day?

1. Recently Ann Marie had accused me of having sex with Deborah, two other women and that I was gay, I told Ann Marie that I was always faithful to her.

1. Deborah told me that her girlfriend was told by someone at her work that Deborah was having sex with me and also her husband that she has been separated from since 1995.

1. Jackie MacKay’s statement continues: About a month ago Ann and Blair separated and that’s when things seemed to do down hill. Debbie Hawkes would come to the __ to see Ann Marie and would phone looking for her. Ann Marie told me it was all related to Blair.

1. Ann Marie told me a couple of weeks ago that she needed two weeks to decide whether we would separate or not.

1. On July 15, 2003, I had a doctor’s appointment, as I had my licence unlawfully suspended since May 3, 2003 for 90 days, Deborah Hawkes drove me to my appointment and as we missed the pharmacy, dropped my prescriptions off to Ann Marie, at my request, however, it was early morning when she remembered, 2:30 am the next morning.

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1. One day after that, I asked Deborah to go and talk to Ann Marie for me and on August 9, 2003, Ann Marie, came over to Deborah Hawkes’s house, after work, at approximately 2:45 pm. I had initially hoped that Ann Marie and I could talk over a few things, especially how we would be looking after our finances, if she made the decision to separate. Deborah and I were working on a civil court case to be heard on August 12, 2003, in regards to the City of Charlottetown. However, after only a few moments Ann Marie and I left together, Deborah keeps extensive notes and this can be verified.

1. Jackie MacKay’s statement continues with: ...Blair started to be more aggressive and forward in his calls. He would say “Is Ann Marie there?”... I never gave him any reason to start a fight...all it would take is someone to be loud to him. He would probably call 20 times over the next month (30 days).

1. Ann Marie works many hours, then she goes to Curves to work out after work and then this summer, she also worked at the hay. My only time to reach her could be at work. With no licence after I returned from Ontario, Ann Marie was one of my only accesses to mobility. Some telephone calls can be verified by a phone bill.

1. Jackie MacKay’s statement continues: We asked her to park her car at my home and my son drove her to work, just so Blair wouldn’t come here.

1. All along I have always dropped Ann Marie off at work when I needed the vehicle for transportation, all along, if Deborah and I would be going into Charlottetown, I would leave the vehicle for Ann Marie, so it would be there when she got off work and Deborah would drive the extra mileage to take me home.

1. When I had my licence returned to me on August 11, 2003, all of a sudden, the vehicle is Ann Marie’s and I no longer have access to it. She changes the ignition and tells me she refuses to give me a key and I am suppose to be OK with that. She states that I took the car one day and was late in returning it to her, that was the day that I had work done on the car, the wheel was that wobbly, it was dangerous for her to drive, I was concerned for her safety.

1. Jackie MacKay’s statement continues: She is so embarrassed and needs to get clear of him.

1. Jackie MacKay’s statement continues: Q. Are you scared of Blair A No, he is only small...and he is really bothering Ann Marie Q. How many times has he been here lately A He is here everyday Ann Marie is working. He doesn’t come to visit anyone else.

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1. How many times did Jackie MacKay tell me to stop calling Ann Marie at work, to stop coming around her work, to stop coming around the residents, answer = zero.

1. There is another statement of Jackie MacKay, this one is also dated August 18, 2003, 13:01 hrs. This statement starts off like the first one, however, it is added: They have a home and he literally gutted it...He is very cautious not to say anything around me. Ann Marie is horrified of him.

1. The Jackie MacKay statement continues: He did all the talking, I think it was last Thursday. It was an argument about the dog. Very forceful

1. Ann Marie took our dog “buddy” who is now an elderly dog, away from his home on Church Rd and left him to the care of her sister’s boyfriend, Trevor, an RCMP constable who was also involved when he was a City of Charlottetown police constable, in my assault and subsequent unlawful arrest on July 12, 2002, the charges against me were stayed. Trevor was telling Ann Marie that I would get 10 years for an unlawful arrest that alleged a stolen car, that charge was dropped on August 7, 2003.

I asked Ann Marie to return “buddy” to his home and look after him and if she was unable to that I would, we have no children, “buddy” is family.

1. The Jackie MacKay statement continues: Did Ann Marie mention to you that she did not want any contact with Blair? A4 No not really?

1. On the victim information form dated August 18, 2003, occurrence date August 17, 2003, possible arrest/Peace Bond. Person(s) charged: (SUI) Victim attended the office requesting a peace bond be put in place against her husband. He is calling, harassing, stalking her since they separated in May. During the interview she disclosed an assault which happened on July 29^th matter is SUI (Still Under Investigation).

1. Continuation Report of Cst. Leslie Dill 48099 dated August 17, 2003, sui 2003-08-22, Page 4. She is only looking for an 810 CC but I think there should be an assault charge here.

1. Continuation Report of Cst. Leslie Dill 48099 dated August 17, 2003, sui 2003-08-22, Page 3. Mrs. Ross only wants and order put in place to keep him away from her because she feels if he is charged he will become more angry and (voilent) toward her.

1. Continuation Report of Cst. Leslie Dill 48099 dated August 17, 2003, sui 2003-08-22, Page 1. After taking the statement writer (belives) there has been an assault take place and is in the process of charging Ross with assault.

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1. The clothes that are mentioned in my note to Ann Marie dated August 14, 2003, I believed were mine, when Ann Marie mentioned some of her things were in the bag, I immediately returned them to her.

1. Statement of Ann Marie Ross, dated August 16, 2003 15:10 hrs. states: we are separated now we have been since May 9, 2003

1. After my 4^th unlawful arrest, assault by 7 RCMP constables, where I was kicked in the head, etc., on May 3, 2003, I left to go to Toronto, to live with the homeless. I was frightened for my life. I am being denied my right to Life, Liberty and the Security of Person I need in order to live free from fear by PEI Provincial Police Members, who take an oath to ensure my Charter Rights and Freedoms under PEI Legislation, Police Act.

I lived with the homeless in Toronto for approximately one month. I was in contact with Ann Marie by telephone on numerous occasions in that month. In order to return home Ann Marie had to send me $500.00. I know that, as my wife, she sees the pain and suffering that I feel. I told her that if she wanted me to come home, to send $500.00 and she did. My daughter accompanied me. I am concerned for the homeless in Canada. (EXHIBIT C)

1. Statement of Ann Marie Ross continues: when I started to pull away, he must have noticed because I have been getting nothing but grief since.

1. Ann Marie has indeed become distant from me, I only wished to do everything that I could to ensure that she realized that I wanted our relationship to work out, she refuses to talk to me, I now believe that I have done all that I could do and I am only in contact with her in writing.

1. Statement of Ann Marie Ross continues: Jackie MacKay and Tess Kivego both have received phone calls from Blair. They say he is upset and very agitated, they won’t tell me exactly what he says but they are starting to question if it is safe for me to be working alone.

1. Where Ann Marie works, it is imperative that no employee work alone.

1. Statement of Ann Marie Ross continues: He phoned work twice about 6:30am and then around 10:00 Tress got the first one Jackie got the second.

1. Statement of Ann Marie Ross continues: Between 2:00 - 3:00 pm yesterday he stood across from my parents home in Peakes...

1. I had received a call from Aaron Koleszar asking if I wished to go to Charlottetown, as I was on my bike and exhausted, we made a plan to meet in Peakes. Aaron was late, I had to wait there. (EXHIBIT D = note from Aaron Kolezcar) .../6

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1. Statement of Ann Marie Ross continues: I have been keeping a diary and writing it down every night, but sometimes I am so frustrated by the end of the day with him, I forget.

1. I wish to have disclosure of this diary. Ann Marie then goes on to describe an event in our home on Church Rd. that a police constable believes is an assault. There are many questions to be answered in regards to this event. I have always been responsible for my actions. Our marriage is between two people this is a 50-50 deal.

1. Statement of Ann Marie Ross continues: I couldn’t find anyone else to take him sooner.

1. This statement is in reference to after the alleged assault. Deborah Hawkes never got a call from Ann Marie to come and pick me up.

1. Statement of Ann Marie Ross continues: Everything seems to be happening all at once and I can’t keep track of everything.

1. Statement of Ann Marie Ross continues: Q Are you scared of Blair? A. Sometimes yes, and it is getting more frequently lately. Q Has he ever made any threats to hurt you? A. Other than that night no, but the way he says things I know what he means Q Do you think he could hurt your parents? A Not physically, but he might try to intimidate them. I am at the point I don’t know if he would burn something down or what he would do?

1. I would do nothing.

1. Statement of Ann Marie Ross continues: There are nights when I don’t know where he is, they are harder than the nights when I know where he is or what he is doing. There are some nights when I am up all night wondering what to do what’s going to happen.

1. Ann Marie could talk to me. I am trying to stay in a place of love in regards to our relationship as I know that she is under a lot of stress.

1. The following statements were spoken by me for the most part to Judge Nancy Orr on August 21, 2003 and the Crown Prosecutor, however, I am still being unlawfully incarcerated against my Charter Rights and Freedoms.

1. My main concern is to plea innocent and to be released from custody so that I can prepare a proper defence for these current charges, I am wanting to answer to today.

1. AM I GOING TO BE RELEASED FROM CUSTODY AND ALLOWED TO PREPARE A PROPER DEFENCE TODAY?

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1. I am being forced to act on my own behalf - due to personal experiences with the justice system, here on PEI, AND KNOWING THE EXPERIENCE OF OTHERS.

1. I, now, as in the past, request a Constitutional lawyer, as my Constitution of Canada Charter of Rights and Freedoms are being infringed and denied. MY LEGAL RIGHTS Sections 7, 8, 9 AND Section 10. (a), (b) and (c) and Section 11 (a) and (d) and Section 15 DISCRIMINATION.

1. Everyone is well aware of the fact that I act on my own behalf and instead of ensuring my Charter Legal Rights, as the oath that is taken to be consistent with the PEI Police Act states, my Charter Legal Rights are continually being infringed and denied and my only recourse is civil litigation where I again am forced to act on my own behalf.

1. I have been given NO help to know how to ensure my release today.

1. It is commendable the concern for the safety of my wife that has been shown, however, this concern is at my expense.

1. My wife and I have been experiencing a great deal of stress since our marriage of four years, and we have been together for 14 YEARS. In particular we have been experiencing financial stress, due to the fact that I am an injured worker who has been deemed and have had my income stolen from me from the Workers’ Compensation Board of PEI.

1. My wife also works very hard and long hours at the Shady Rest, a private home for the aged, she has a low wage and few benefits at this employment, however, she enjoys her work and is quite knowledgeable in her field of career and in the past few months, also helped put in hay.

1. Due to lack of an adequate income , the high cost of living today, especially with transportation costs, as a couple, we have debt, I AM AN INJURED CARPENTER and our home has deteriorated at an alarming rate.

1. There is no evidence before the court nor will there ever be that I ever assaulted my wife or will assault her in the future.

1. However, if a trial proceeds with these charges, the behaviour of my wife caused perhaps from stress from many areas will become apparent and the charges will be dropped, dismissed or I will be acquitted.

1. My seventh unlawful arrest and assault by RCMP constable Eveleigh at approximately 1pm on August 18, 2003, has caused me intense emotional and physical trauma.

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1. August 18^th is my wife, Ann Marie’s Birthday, I had purchased her a Birthday Card, and had just arrived at Deborah Hawkes’s home to begin to prepare for Trial on August 26, 2003 **I will speak to this further**. As Ann Marie and I had only recently separated, I intended to drop the card off at the office where Ann Marie works.

1. My Legal Right, Charter 10 (a) to be informed of the reason for detention was denied.

The question is whether the detainee was told, viewed reasonably in all the circumstances of the case, was sufficient to permit him to make a reasonable decision to decline to submit to arrest, or alternatively to decide whether or not to exercise his right to consult counsel:

1. I SAW no arrest warrant. No charges in writing. What the constable was telling me without allowing me the benefit of a witness was a shock to me. I simply asked him to tell me with a witness present, instead he assaulted my person.

1. Then I was also subsequently assaulted, so soon after that initial assault, as I was unlawfully abducted from the home of Deborah Hawkes by numerous RCMP constables, has caused me intense emotional and physical trauma, thus pain and suffering, grabbed by the throat and hauled around, etc..

1. My subsequent unlawful detention at the RCMP station in Montague for over 3 hours (where I was even denied access to full disclosure of the information from my wife’s charge) caused me intense emotional and physical trauma, thus pain and suffering and I asked to see a judge.

1. My subsequent unlawful remand in custody by justice of the peace, S. Clory, caused me intense emotional and physical trauma, thus pain and suffering.

1. I was denied medical attention, but the person who assaulted me was given medical attention and I am still being denied medical attention and the ability to document the bruises, cuts, etc., that I received in my assault by RCMP constables.

1. When I am unlawfully incarcerated, I experience intense emotional and physical trauma, thus pain and suffering not, but the fact that I was an inmate at Mt. Herbert Orphanage at

an early age and incarceration triggers the trauma I experienced almost 40 years ago.

1. MY SHOW CAUSE HEARING ON Tuesday the morning of the 19^th, 2003 heard by the Prothonotary Charles Thompson, at 9:30 am, infringed and denied to me my Charter Legal Rights, in particular 11(d).

1. I was still in shock from the experience of the assaults, unlawful arrest and unlawful incarceration and the re-trauma I experience.

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1. I was denied full disclosure in regards to the charges involving my wife.

1. I saw nothing in writing.

1. I was simply read the charge and the crown read some disclosure. This is his job, my job is to ensure my release from unlawful incarceration.

1. I was denied any assistance that I could trust or any time to prepare a proper show cause hearing as I was acting on my own behalf.

1. My request for medical attention was denied and still denied.

1. I am told that my only recourse after the Show Cause Hearing was to make an application for review from the PEI Supreme Court, to give the crown two full days notice and I would still be dealing with a corrupt, political patronage justice system.

1. It was unlawfully determined that I would stay in custody and when I was returned to the Correctional Centre, I was placed in Maximum security.

(EXHIBIT E = Graphic article and EXHIBIT F = Guardian article)

1. There was no evidence before the court nor will there ever be that I ever assaulted my wife or will assault her in the future.

1. The Crown is well aware of the fact that I have no prior record whatsoever since 1985 and there is no record of assault.

1. However the Crown is also well aware of the fact that the first time that I was unlawfully arrested, denied medical attention, discriminated against by being unlawfully incarcerated, had many Charter rights infringed and denied, on July 18, 2001, when I was charged with trespassing to stop my 64 day hunger strike, peaceful political protest and the charges were dismissed by Judge Douglas in November of 2001 and little was ever done to prevent this from happening again accept for the fact that a designated tenting area was established until Christmas arrived and again my Charter rights were allowed to be infringed and denied. (Exhibit B = photo of Brigade needed to remove myself and two women)

106. On June 17, 2003, I was handed a summons to a person in regards to a fifth unlawful arrest charge in regards to a stolen car. .../12

106. My wife, Ann Marie was in shock after this unlawful charge, as she knew nothing of a stolen car.

106. Her shock is similar to the shock that I experienced on August 18^th with the assault and harassment charges laid against me.

106. This stolen car charge was in the Guardian twice and made the Front page of the Easter Graphic (EXHIBIT L = Two Guardian articles AND EXHIBIT M = Eastern Graphic article)

106. This unlawful charge was dropped on August 7, 2003, however, in that two months, Ann Marie had to endure much negativity in regards to me, her husband, Blair Ross, NOTHING WAS PRINTED IN THE GRAPHIC AND THE GUARDIAN MADE A SMALL MENTION OF IT.

106. Ann Marie heard very little by way of positive phrases in reference to me. I believe she was told by Trevor ______ a RCMP officer, a past City of Ch’town constable involved in my assault on July 12, 2002, and a few others, that I would receive 10 years in prison.

106. On August 13, 2003, I was unlawfully arrested, my property damaged and unlawfully incarcerated, similar to my experience on July 10, 2002.

106. This UNLAWFUL ARREST was done by one of the RCMP constables who was present during my assault by the RCMP Constables on May 3, 2003, Mario Gallant, a constable familiar with the breathalyser.

106. This unlawful arrest and unlawful incarceration caused me intense emotional and physical trauma and the re-trauma of Mt. Herbert Orphanage, thus pain and suffering.

106. I AM CURRENTLY IN NEED OF FULL DISCLOSURE IN ORDER TO PREPARE MY DEFENCE AND AM SUMMONED TO PLEA INNOCENT ON SEPTEMBER 29, 2003, SO THAT THIS CHARGE WILL BE DROPPED, STAYED OR I WILL BE ACQUITTED.

106. It is ironic, that my wife, Ann Marie, has the ability to lay charges against me and to have such a negative effect on my life.

106. I would like to be afforded the ability to charge those constables and other personnel who have emotionally and physically caused harm to me. (EXHIBIT N = Deborah Kelly Hawkes inability to have justice served for her assaults)

106. It is ironic, that my wife, Ann Marie, has the ability to lay an assault charge against me, I know well the trauma that one experiences when one has been raped or could experience from an attempted rape. (EXHIBIT O = Orphanage information, 6 pages)

106. Ann Marie, has been under a lot of stress and her behaviour and other accusations in regards to me, from this stress and from the influences of others, will be brought out in the trial, if this charge ever goes to trial and I will be acquitted, I am innocent until proven guilty, yet I am being punished by using extreme measures.

106. I insist on being released on the reasonable conditions of an undertaking, which is my right and the request and the need of my wife, Ann Marie.