0 99 SULA? a7 Court File No. A-48-16 FEDERAL COURT OF APPEAL ip COUR D'APPEL — Loa thao |B FEDERAL COURT OF APPEAL BETWEEN: DAVID RAYMOND AMOS Plaintiff/Respondent on Cross Appeal and HER MAJESTY THE QUEEN Defendant/Appellant on Cross Appeal RESPONSE OF DAVID RAYMOND AMOS TO THE SUBMISSIONS OF HER MAJESTY THE QUEEN PURSUANT TO THE JUNE 8, 2017 DIRECTONS OF THE FEDERAL COURT OF APPEAL DAVID RAYMOND AMOS NATHALIE G. DROUIN P.O. Box 234 Deputy Attomey General of Canada ESP 3G2 Department of Justice Apohaqui, NB per: JAN JENSEN | Suite 1400, Duke Tower 5251 Duke Street Halifax, NS B3J 1P3 Telephone No: (902) 800-0369 Telephone No: (902) 426-8177 Fax No: (506) 432-6089 Fax No: (902) 426-2329 Email: David Raymond.Amos@gmail.com Email: Jan.Jensen@justice.ge.ca } Plaintiff on his own behalf Counsel for the DefendantFACTS 41. The Plaintiff/Respondent is grateful for the July 7, 2017 directions of the court permitting his June 26, 2017 submission to be filed thereby allowing this response to be filed in a timely fashion pursuant to the June 8, 2017 direction. After filing his, brief the Plaintifi?Respondent became aware that two more lawyers whom he has a conflict of interest with were appointed to sit on the bench of Federal Court on the very same day he had been ordered to file his brief, They are William F. Pentney the very lawyer who has received all of the filings in this matter until today. The other is John B. Laskin, a lawyer whom the Plaintifi/Respondent has contacted and spoken to personally in the past about several different matters. The Plaintiff/Respondent must Update the list of Judges he truly believes that he has a conflict of interest with. The list is as follows: Justices William Pentney, John Laskin, Richard Bell, René LeBlanc, Henry Brown Catherine Kane, Richard Southcott, Glennys McVeigh, Alan Diner, Denis Gascon, Martine St-Louis, Cecily Strickland, Sylvie Roussel, Anne Marie McDonald, George Locke, Simon Fothergill, Keith Boswell, Yvan Roy, Yves de Montigny, Russel Zinn, Donald Rennie, André Scott, Richard Boivin, Patrick Gleeson, Mary Gleason, David Near, Wyman Webb, and David Stratas 2. The Crown counsel, Jan Jensen acting on behalf of Her Majesty the Queen, the Defendant/Appellant (CROWN) is well aware that the Plaintifi/Respondent’s name is David Raymond Amos (AMOS). He is proud to the namesake of RAYMOND his Unele who was killed defending the CROWN on June 8th, 1944 in Normandy. 3. On AMOS considers the CROWN's argument with his brief as a fruitless attempt to negate his concems about a conflict of interest he has with judges who were in private practice and all the others who were employed in government service before being appointed to the Federal Court and the Federal Court of Appeal. Justice David Near should recall that the AMOS addressed his concerns about a conflict with him twice during the course of the hearing on May 24, 2017 and Justice Near did not respond, What the CROWN claims within its submission is not true.4, On May 24th, 2017, AMOS during the hearing reminded the Justices at least twice of rules 5 (4) and 5.1(4) of the Federal Courts Act and did his best to inform the judges of a case management teleconference of Federal Court on April 3, 2017 and strongly suggested that they confer with Justice Leblanc before making any decision in this matter. The following information was copied from the published record of Federal Court Court Number:T-187-15 DAVID RAYMOND AMOS v. HER MAJESTY THE QUEEN ‘Office Halifax Dated filed 2077-04-04 “Oral directions received from the presiding judge dated 04-APR-2017 directing that “Burther to the letter from counsel for the Defendant, dated March 30, 2017 and to the case management teleconference held with the parties on April 3, 2017, the Plaintiff's motion, returnable April 10, 2017 in Fredericton, New Brunswick, seeking an order "affirming or denying the conflict of interest he has" with a number of judges of the Federal Court, is premature and, therefore, adjourned sine die as the issue of whether the Plaintiff's Statement of Claim discloses a reasonable cause of action is currently before the Federal Court of Appeal and could result in the dismissal of Plaintiff's action. To the extent that the Plaintiff's motion seeks an order “affirming or denying the conflict of interest he has" with a number of judges of the Federal Court of Appeal, the said motion is beyond the jurisdiction of the Federal Court and will not be entertained." placed on file on 04-APR-2017 Confirmed in writing to the party(ies)"4, Whereas the CROWN with its submission has provided as an authority a copy of Committee for Justice and Liberty et al v National Energy Board et al, {1978] 1 SCR 369, 1976 Can LII2 (SCC), AMOS continues to rely on the decision of Justice Bell to support his Appeal of Justice Southcott’s ations and every other judge he has met in court since January 11th, 2016. The portion of the December 14, 2015 decision of Justice’ Bell that should be considered by all the judges that the Plaintiff/Respondent named within the first statement of this submission is as follows "In the circumstances, given the threat in 2004 to sue me in my personal capacity and my past and present relationship with many potential witnesses and/or potential parties to the litigation, I am of the view there would be a reasonable apprehension of bias should I hear this motion. See Justice de Grandpré’s dissenting judgment in Committee for Justice and Liberty et al v National Energy Board et al, [1978] 1 SCR 369 at p 394 for the applicable test regarding allegations of bias. In the circumstances, although neither party has requested I recuse myself, I consider it appropriate that I do so. 7. The Plaintiff/Respondent pleads that the Federal Court of Appeal deny the latest. attempt of the CROWN to have this matter dismissed and to revoke its decision ing his appeal of Justice Southcott's actions. 8, AMOS states that this matter is not frivolous or vexatious and that he has every right to see his complaint against the CROWN to go forward to trial to be judged on its merits and heard by Justices who donot have a conflict of interest with him.ALL OF WHICH IS RESPECTFULLY SUBMITTED DATED at Fredericton, New Brunswick, this the 14" day of July, 2017 il han DAVID RAYMOND AMO: P.O. Box 234 Apohaqui, NB ESP 3G2 Appellant/Respondent on his own behalf TO: Administrator, Federal Court of Appeal AND TO: NATHALIE G. DROUIN Deputy Attorney General of Canada per: JAN JENSEN Department of Justice Suite 1400-Duke Tower 5251 Duke Street Halifax, NS B3J 1P3