Response for the insurance Lawyer Harry Brown factum has been served and filed to the fsco arbitration hearing( other insurance victims may use this information helpfull for their file)

Response of the unica Insurance materials that has been prepared by Unica insurance lawyer Harry Brown (factum,document brief of the applicant,book of authorities)
1-)This factum and other documents can not be admitted and used on this arbitration hearing
2-)This factum and other documents are not relevant with this hearing ,therefore those subjects are related to the 3th person and some one else’s case,this factum should have been taken out from this hearing and these documents are not admissible.
4-)interfering some one else’s ongoing law suit is not business of this arbitration hearing.Reasons are why this factum can’t be used ,that has been clearly stated one by one below.
5-)Also uttering forge documents,misleading justice ,perjury and violating privacy act is a crime.Those crimes occurred as son these materials are prepared and served to the FSCO.
6-)This documents are full of criminal materials so can not be admitted to this hearing.
7-)If arbitrator King or fsco let these materials to be accepted and used on this hearing,that makes Arbitrator King and FSCO will be shared responsibilities of criminal act for admitting and letting this documents to be used.
There fore I keep my rights to fill up a private prosecution particulars against who ever responsible and be part of this criminal act,also I will make attorney general to be involved with this situation along with other organizations.

A-)Factum 2-3-4-5
1-)They are saying that mr.Ozdemir is my attendant care and I am his attendant care.
they brought as a witness insurance adjuster and a hired pen of a company who says that this signature is mine on forged ocf 6 form.
2-)Where they with me while this documents were prepared and signed?Did they see me while this document is signed or prepared?
3-)If I say those ocf 6 is not mine ,that means it is not mine,where is your witness? who saw me by signing those ocf6?
4-)You are saying Erol Ozdemir is my care giver.What is your evidence?
Have you prepared forge ocf6 for Erol Ozdemir too?
5-)Do you have any ocf 6 that has been signed by Erol Ozdemir says he is my Care giver?
6-)Did Erol Ozdemir claim anything from the unica insurance if he is my Care giver?
7-)All Bold accusations with no ground.
B-)Factum 17-18
Harry Brown already mentioned about the arbitration transcripts on his factum number 17-18
1-)I told arbitrator Robinson when he asked me who is my attendant care,I said my wife and Erol Ozdemir,it is obvious beside my wife Erol ozdemir is supporting me by socializing ,attending with me to the doctor appointments,I have never said that Erol Ozdemir taking care of me physically,he never give me a shower,my wife does,he never brush my teeth ,my wife does,he never shave my beards ,my wife does.If there is my wife ,why would I receive care giving services from someone else ,does that make any sense?
2-)If you take a look at the Dr.Gerber report you will see that collateral informations,has been skipped by Harry Brown.My wife and Erol Ozdemir was there and gave evidence to the Dr.Gerber for the CAT report.
3-)Also my wife was at the Dr.Siva’s clinic to gave evidence as collateral information about my situation.
4-)You are miss interpreting my words on purpose here,
5-) We are not arguing about wether or not Erol was care giver ,we are here to argue if I was his care giver after my accident.
6-)I answered clearly to arbitrator Robinson question ,I say first my wife she is my primary care giver ,second Erol ,who is supporting me by attending to the arbitration hearing,attending doctor appointments ,etc.
7-)I never said that he was physically helping me. it has been clearly states there what kind of help that I am getting from Erol Ozdemir,read that carefully and try to understand.Also it clearly states there on that transcript tab4 page 79-87 Arbitrator Robinson asked me while my wife was away ,who was doing house keeping and such tasks,I clearly states there Erol Ozdemir was paying for it to be done ,he was hiring people to do those tasks,house keeping or attendant care.
C-)Factum 23-24
That has been already explained and Erol ozdemir has no single testimony to no one about being a care giver of me ,this is mentioned by Erol Ozdemir on CAT report ,if you look at the collateral information on dr.Gerber reports ,Erol Ozdemir always says that he brought person or hired person to make them do such tasks while my wife was away.
Erol Ozdemir did not do any help physically to me.
You are just assuming on this Factum 23-24
D-)Factum 25
Judy Philips Was at the hearing I believe as a witness who came and gave her testimony and Arbitrator Robinson found that evidence was given by her wasn’t credible so,what is wrong with that?
E-)Factum 26
1-)As you say I didn’t bring any doctor to the hearing ,I did not know that my lawyer was going to be bought by Unica insurance ,until that morning of the arbitration hearing I didn’t know my lawyer was sold out and he was not going to show up for the arbitration hearing.
2-)I did not know of processing of the arbitration ,I wasn’t aware of calling doctor or summon witness forms.
3-)Now I bring my doctor so ,decision must be change regarding this issue.
F-)Factum 27
Those inconsistencies belong to Harry Brown, you are the one who creates these inconsistencies.Simply a Harry Brown has created a fake world and decided to live in it and he is expecting me to join him and expecting everyone else to join him ,I believe Harry Brown has serious issues with his mental health so,I suggest him to go and see a doctor for it.
G-)Factum 28
1-)Again I am repeating my self ,those documents don’t belong to me ,and I did not sign those documents or put the dates on it ,not even my hand writings ,there are forged documents has been prepared by unica insurance or economical or both,are there any witness where and when I signed or fill up those ocf 6 papers?
2-)Did any one saw me or did I sign those documents front of someone ?
3-)I can’t simply prepare those documents and sign ,there must be someone present and I believe there was no one so,that means I printed those documents and filled up by my self and send them to the insurance company and asked them to pay me ,that must be a story of a fairy tale.
4-)As long as you can’t bring a real witness to the hearing and testify that he or she was presenting there when I sign those documents,your bold accusation is only become assuming ,anywhere in the world law doesn’t work by assuming or accepts assuming
H-)-Factum 29
Application for mediation has been prepared by Erol Ozdemir’s Lawyer ,I wasn’t aware of my name is used there.if the document is real,I don’t have any signatures there ,on the document says client signatures there ,what I see client signature section is empty ,I am not responsible about some documents has been prepared served by some on else’s case,that doesn’t proof anything ,I didn’t prepare or serve that mediation application paper.It is not my problem.
Also that individual lawyer has started working against his client by cooperating with the insurance lawyer ,so around those days I believe that lawyer he’s been fired.

I-)Factum 30
Probably mediator saw those ocf 6 belongs before my accident so he may put my name there ,again that doesn’t mean I am the service provider for Erol ozdemir
After my accident occurred ,beside this ,before my accident,I was ,my wife was and Ghanna was taking care of Erol Ozdemir and after my accident as my letter says I can’t take care of anything for him only Ghanna left for him as a service provider.
J-)factum 31
That ocf 6 is a forged document and I never accepted that document has been signed or dated by me and there is no evidence that can proof otherwise.
K-)-Factum 32
As you say first time this forged documents has been brought front of me at the Judge Emery motion and as you see judge Emery says ,I do not accept those forged documents has been signed by me or dated by me.
L-)Factum 33
Let’s read what I have written to the Tripta Sood ,if I am charging money any one ,it is my business no one else’s,I can charge any one any money for being beside him,standing with him ,sitting with him or drinking coffee with him,if Brown wants to drink coffee with me I can charge him 10.000$ ,if the arbitrator wants to drink coffee with me my price will be 20000$ ,if Insurance adjuster wants to walk with me or stand beside me I can charge him or her 100000$
I don’t see any problem in here ,my business is my business,no one can stick their nose in to my business.That is my freedom.
M-)Factum 34
EMails between one insurance lawyer to the other one is their business ,I don’t care what people say about me or about Mr.Ozdemir,any one can say anything,specially insurance side.
N-)Factum 37
1-)On Those surveillance I am breathing too,does that means I am ok?
2-)Surveillance shows only small part of my life,I never said I can’t walk or I can’t carry grocery,that doesn’t mean I am not suffering because of pain ,next day I can’t even get up from the bed.Because of carrying grocery bags.
3-)I couldn’t hire any one to carry them for me.Insurance should have paid money to me and then I can hire some one to carry grocery bags for me.
4-)Obviously arbitrator Robinson skip these parts of my life,no one can be same everyday ,I never said I am same all the time or everyday.
One day I have less balance problems,I can go for a walk, next day more balance problem I can’t even go out for a walk,I stay home all day long.
One day I feel too much pain ,next day I feel little better and feel less pain so ,I can decide to do grocery that day and I do grocery,I have to eat like everyone else and no one bring those grocery for me.
5-)Therefore I am requesting extra money from the unica insurance to be able to hire a person to bring groceries for me.
O-)Factum 38
Same Lisa Duffus also says that I need 6000$ for ongoing Attendants care,let’s consider this too.
P-)Factum 42
Surveillance was not everyday 24 hours a day ,surveillance doesn’t show everything or proofs anything.
Surveillance doesn’t come with me to the doctor office or in my apartment or on my bed,surveillance doesn’t proof anything about my life.
R-)Factum 43
Again repeating same bold accusation says we are each other service provider ,is there any evidence or any signed ocf 6 has been signed by Erol ozdemir that he is my caregiver?
Any more forge ocf6?

S-)factum 49
This transcript can not be used in my arbitration ,it is illegal to use,there should be a judge order for them to be able to use 3th person transcript ,there was no motion has been brought them to use this transcript ,therefore Erol Ozdemir is keeping his right to make a formal complaint to the privacy commissioner or justice of peace for violation the privacy act. And access to information act.
Here is the law
Protection of Personal Information
Marginal note:Use of personal information

7 Personal information under the control of a government institution shall not, without the consent of the individual to whom it relates, be used by the institution except
(a) for the purpose for which the information was obtained or compiled by the institution or for a use consistent with that purpose; or
(b) for a purpose for which the information may be disclosed to the institution under subsection 8(2).
1980-81-82-83, c. 111, Sch. II “7”.
Marginal note:Disclosure of personal information
8 (1) Personal information under the control of a government institution shall not, without the consent of the individual to whom it rela

Access to information act

Personal Information
Marginal note:Personal information
19 (1) Subject to subsection (2), the head of a government institution shall refuse to disclose any record requested under this Act that contains personal information as defined in section 3 of the Privacy Act.
Marginal note:Where disclosure authorized
2) The head of a government institution may disclose any record requested under this Act that contains personal information if
(a) the individual to whom it relates consents to the disclosure;
(b) the information is publicly available; or
(c) the disclosure is in accordance with section 8 of the Privacy Act.
1980-81-82-83, c. 111, Sch. I “19”.

1-)Where is Erol Ozdemir transcript of discovery ,I can’t comment on it because I haven’t received that transcript,also says that Erol Ozdemir doesn’t accept any attendant care has been given him by me,this is inconsistent what you are claiming on this hearing.
2-)Erol Ozdemir transcript should be testified need cross examination of Tripta Sood and Erol Ozdemir.
3-)Have you called Tripta Sood for testimony and cross examination?
T-)Factum 50
1-)Who is Erhan Altayoglu?Has he been testified anywhere?
2-)Did you bring him to the court before ,or here at the arbitration?
3-)I don’t know him or remember him ,neither Erol Ozdemir does.
4-)probably this Erhan Altayoglu is another guy who has been hired by the insurance company.
5-)What he says also inconsistent with the what ever you are claiming here.
6-)Is this arbitration revocation hearing for me or for Erol Ozdemir?
U-)Factum 51-52 Ghanna
1-)If you look at her documents has been signed by her ,The document has been prepared and signed at the time of Tripta Sood requests ,Feb10-2010 is misprinted
2-)if you look and read the whole page it is clearly says that since when she has been taking care of Erol Ozdemir as an attendant care.
3-)This document is not fraud nor Ghanna herself.
4-)But how ever this subject is outside of the case,we are not here to talk about who is Erol Ozdemir’s Care giver and What does she do.
5-)We are here for accusation of ,if I have been Attendant Care of Erol Ozdemir after my accident occurred.
V-)Factum 54
It is related to my blog ,thx for finding my blog is intrested like other 160000 followers world wide.Again this is not relevant with this hearing.
W-)Factum 55 There is no need to talk about it.
Giffing report can not be admissible,that report never used on the Tort hearing and the person who prepared that report never came and testified his report in any court.
How ever that report shows how serious the accident was and i wished that was used in my tort hearing.The report has been prepared by person whom hired by tort insurance lawyer ,Some how insurance lawyer has changed his mind to use this report at the tort hearing ,how ever the report has been served and filed for the tort hearing by the insurance lawyer.
X-)Factum 59
It is related to the fake ocf 6 and one more thing added to the accusation which is house keeping ,is there any other documents that has been signed for the house keeping or you are now trying to add house keeping services on me for the Erol Ozdemir.
Any evidence for the house keeping services?
Y-)Factum 59
It is also related to the bold accusations and related to the forge documents ocf 6 ,some how they really believe themselves that this documents are real and some how they thought it causes inconsistency with arbitrator decision.Some thing that doesn’t exist ,how could be inconsistency with the arbitrator Robinson’s decision.
Sent from my iPad


Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

This site uses Akismet to reduce spam. Learn how your comment data is processed.