In the Holy Name of Iran
Major, Keyvan, Nourhaghighi
Iranian, Senior, Fighter Pilot
Tortured numerously by Toronto Police
Major's Galerie, Poetry, Meydody, Obe
Corrupt Canadian Physicians and Hospitals
Salam Islam, Imam Ali, Erfan-Sufi-Rumi, Sport
Canadian Corrupt Judges & Crown Lawyers,
Canadian Corrupt Lawyers, Police & Pilots
Architects, Bankers, Physicians & Owners
Canadian & Persian Counter-Dictionary
Conseil de la magistrature du Quebec
Corrupt Ontario Judicial Council
Queen&Corruption in Canada
Major's Selections; Articles
Victims of Police Brutality
Toxic Mould in Condo
O'Canada! Land of Frauds
Canadian Constructive Industry
Major, Keyvan, Nourhaghighi
Iranian, Senior, Fighter Pilot
Tortured numerously by Toronto Police
Major's Galerie, Poetry, Meydody, Obe
Corrupt Canadian Physicians and Hospitals
CONFIDENTIAL
Major Nourhaghighi Encyclopedia 2016Salam Islam, Imam Ali, Erfan-Sufi-Rumi, Sport
Canadian Corrupt Judges & Crown Lawyers,
Canadian Corrupt Lawyers, Police & Pilots
Architects, Bankers, Physicians & Owners
Canadian & Persian Counter-Dictionary
Conseil de la magistrature du Quebec
Corrupt Canadian Judicial Council
Corrupt Ontario Judicial Council
Queen&Corruption in Canada
Major's Selections; Articles
Victims of Police Brutality
Toxic Mould in Condo
O'Canada! Land of Frauds
Canadian Constructive Industry
Canadian Counter-Dictionary, and Human Rights' Violations in Canada
Three British Bastards Left No Dignity for Canadian
VIVA FREE CANADA
Author Note:
Murder, Torture and Sexual Assault by agents of the Whore Elizabeth II in Canada are common practice. The corrupt Police , Crown and Judges, are only may charge and convict "Immigrants" IF they sexually assault a White British Teenager.
IN other word, all immigrants and even color citizens have no protection under Canadian Law for Rape and Sexual Assault, PARTICULARLY MALE IMMIGRANTS!
Yes!, most of British Judges, Lawyers, Cops, Doctors and Government Staff are GAY; and their Daughters and wives are Whore! So they love to get sex with Immigrants.
They are very aggressive and without any shame touching Immigrants' sexual body parts in Streets, Malls, Government Offices, Court, Police Divisions, Schools etc. AND, clearly, asking " Give it to me , " Can I have blowjob!", "Im honey get $100 and fuck me!" " I love your Dick" etc.
Murder, Torture and Sexual Assault by agents of the Whore Elizabeth II in Canada are common practice. The corrupt Police , Crown and Judges, are only may charge and convict "Immigrants" IF they sexually assault a White British Teenager.
IN other word, all immigrants and even color citizens have no protection under Canadian Law for Rape and Sexual Assault, PARTICULARLY MALE IMMIGRANTS!
Yes!, most of British Judges, Lawyers, Cops, Doctors and Government Staff are GAY; and their Daughters and wives are Whore! So they love to get sex with Immigrants.
They are very aggressive and without any shame touching Immigrants' sexual body parts in Streets, Malls, Government Offices, Court, Police Divisions, Schools etc. AND, clearly, asking " Give it to me , " Can I have blowjob!", "Im honey get $100 and fuck me!" " I love your Dick" etc.
Since 1990, hundreds Canadian Male and Female are committing all kinds of unwanted Sexual Nature Torches and clear Sexual Assaults against me.
The Corrupt Toronto Police never charge them, and in my first report to 52 Division that a
woman torched my genital without my consent. The Cop receiving my complaint Laught and Several time asked me " A Woman touch you and you expect we charge her. What about us! If we touch you then who is going to charge us! Then fw cops in reception area all laughed.
These Bastard Cops, Lawyers and Judges under Leadership of Whore Queen NEVER had Dignity to understand that a Person Dignity is MUCH HIGHER than Sexual Need and when a person ask for a " Consent" to engage in sexual activity. The person self esteem and dignity will be maintain, it has nothing to do with age and sex of person, man or woman. Same as the corrupt the President of University of Toronto, that all its bastard Staffs, Instructors, and corrupt professors are daily sexually assaulting students and members like me; and when we complain, they are changing the story and saying " there is no Witness to support your complain, and it is better you dint go to that class, Gym, Library etc".
However, the Canadian Doctors, are worst animals, as they abuse their Office Authority for Sexual Abuse. The Immigrants Patients and I, must perform a regular Check Up that allows they Perform Examination According to the Professional Code.
In Germany, in all medical exam, there is an assistant beside every Doctor to make sure that He/She does not abuse the Patients.
IN CANADA, there are Over One Hundred Thousands Files of Complaint as Against Male and FEMALES Doctors who have sexually assaulted their Patients and I.
I am not sure how many Male Immigrants have files Complaint against Canadian Doctors, Lawyers, Judges, Polices, Professors, Gym Instructors, Personal Trainers etc for Sexual Assault and Sexual Touches. However, I am proud to be the first Canadian, that from the first professional misconduct, I filed complaints against them.
The following Complaint for Sexual Assault is against a Bastard Doctor NGUYEN, who was the Judges & Cops AGENTS when I had many trials against them, banks and corporations.
So, the corrupt Doctor, who had confident that if commit crime against me, police will protect him. AND at the same time, he could see that I was occupied and stressed for all legal proceedings. So, he gradually commenced sexual touches and continued to move
forward, without my notice. I was always the last Patient, spending a lot of time in chatting and many questions that sound like " cross-examination" and Judges and Lawyers were asked him to ask, and when he was noticing that I have lost my mental alert.
Then was using some kind of Spry in my Noise, alleging it would open my sinus, which indeed was casing dizzy and feeling sleepy, then would take me to exam room, helping me to be nude and .....
The Investigator of the College have obtained all Details and left in confidential way before the Board..... The Bastard Doctor NGUYEN, has closed his Office at 360 College Street in Toronto, and did never practice as Physician
IN the following Table of Content, You will see a Large Number of Court Cases; I have brought that to prove my level of stress and mental anguish in which the corrupt Canadian Doctor Offender
CONFIDENTIAL File No. 8615
Then was using some kind of Spry in my Noise, alleging it would open my sinus, which indeed was casing dizzy and feeling sleepy, then would take me to exam room, helping me to be nude and .....
The Investigator of the College have obtained all Details and left in confidential way before the Board..... The Bastard Doctor NGUYEN, has closed his Office at 360 College Street in Toronto, and did never practice as Physician
IN the following Table of Content, You will see a Large Number of Court Cases; I have brought that to prove my level of stress and mental anguish in which the corrupt Canadian Doctor Offender
++++++++++++++++++++++++++++++++++++++++++
CONFIDENTIAL File No. 8615
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI
Complainant
-and-
DOCTOR KHOI BA NGUYEN, MD
Member Complaint Against
______________________________________________________________________
COMPLAINANT’S SUBMISSIONS RECORD
______________________________________________________________________
The
Complainant, self counsel Major
Keyvan Nourhaghighi
456-608
College Street
Toronto,
ON
M6G
4A3
TO: The Registrar Abby Katz Starr,
151
Bloor Street, West, 9th floor
Toronto,
ON
M5S 2T5
M5S 2T5
Served
to the Registrar on September 29, 2006, at 3:45PM by Personal Service
CONFIDENTIAL
TABLE
NO. DESCRIPTION PAGE
1. First page of Application Record under
Extraordinary Remedies under 1
the Criminal Code: Nourhaghighi
v. R. SM31-06; sat for Nov 14/06
2. Letter From: Nourhaghighi; To: HPARB; January 13, 2005
2
RE: College did not reply to
Complaint…
3. Letter From: HPARB; To: Nourhaghighi; January 14, 2005
3
RE: Board has no power…
4. HPARB Chair Condos’ Decision &
Reasons v. College; April 27, 2005 4
5. Notice of Application; 04-cu-273627CM 6
6. Home
Inspector Heath Hazard Repot 10
7. Endorsement
Court of Appeal for Ontario v. Condo 11
8. Order
of Justice Pitt v. Condo & Caber 13
9. Order
of Court of Appeal for Ontario v. Condo & Caber 14
10. Federal Court Order of Justice LEMIEUX
v. SIRC & CSIS 15
Major Nourhaghighi v. SIRC &
CSIS T-762-04
11. My
Letter to Owners of Condo Re: Toxic Mould 16
RE: Nguyen & College Public
Interests Issue
12. Notes of Dr. Soboloff MD to property manager 17
13. SUBMISSIONS 18
1. Endorsement of Justice Coo June
16, 1995 1
Ontario
Superior Court of Justice: Nourhaghighi v. Toronto Hospital et al
2. Endorsement of Justice Boland March
27, 1996
Ontario Superior
Court of Justice: Condominium 935 v. Nourhaghighi
3. Endorsement of Justice Boland March
27, 1996
Ontario Superior
Court of Justice: Condominium 935 v. Nourhaghighi
4. Endorsement of Justice Day September
1997
Ontario
Superior Court of Justice: Nourhaghighi v. Toronto Police et al
5. Few pages of Justice Cadsby’s Judgment
v. Toronto Police November 1997
Ontario
Court of Justice: R. Toronto Police v. Nourhaghighi
7. Endorsement of Justice Campbell of the June 2,
1999
Federal
Court of Canada: Canada v. Nourhaghighi
8. Order of Justice Lemieux
v. SIRC January
2005
Federal
Court of Canada: Nourhaghighi v. SIRC
9. Endorsement of Justice Pitt, April
26, 2005
Ontario
Superior Court of Justice: Nourhaghighi v.
Condominium 935
10. Endorsement of the Ontario Court of
Appeal January
2006
Nourhaghighi
iv. Condominium 935-applicant
11. Pending Application: Extraordinary
Remedies v. the Crown February 2006
First page of Notice
of Application
12. Concise findings: Commission for
Compliant against RCMP ….. 2006
Nourhaghighi
v. RCMP
The Original Decision is classified
‘Secret’
13. Concise findings of Security Intelligent
Review Committee May 12, 2006
Nourhaghighi v. Canadian Security
and Intelligent Services (“CSIS”)
The Original Decision is classified
‘Secret’
15. Authorities
Judgment against justice of peace
Balckmon for sexcual …
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
CONFIDENTIAL File
No. 8615
HEALTH PROFESSIONS APPEAL AND REVIEW
BOARD (“BOARD”)
BETWEEN:
KEYVAN NOURHAGHIGHI
Complainant
-and-
KHOI BA NGUYEN, MD
Member Complaint Against (“Nguyen”)
COMPLAINANT’S
SUBMISSIONS
PART I
STATEMENT OF CASE
1. I made a request that the Board, in
accordance with law, reviews the unfair, and erroneous Decision 1 of
the Committee concerning my complaint against Nguyen where the inadequacy of
the investigation and biased 2,3,4,5 are few grounds for this
appeal.
2. On September 27, 2006 I got two letters from Starr 6, 7 asking for the grounds of confidentiality, the fresh evidence, and submissions to be filed by 09/29/06; this short notice was unfair. Further, Goldblatt 8 and Pond 9 during telephone conference, consented that hearing be held in the confidential. The burden is upon Osborne 7 to explain why this fact was omitted from her Report; and why on same day of conference did not inform me of the deadline-09/29/06. Osborne refers to Rule 8, but did not send a copy of Rules that I learn all my rights; yet Rule 8 is in the Report; these submissions are satisfying its parameters and considering also the conditions of fresh evidence too.
1 Decision of October 2005 (“Decision”); the Complaints Committee Record
(“M”)
2 The Defendant, the
College of Physicians and Surgeons of Ontario (“College”)
3 Nourhaghighi v. Toronto Hospital et al: 95-CU-84058
3 Nourhaghighi v. Toronto Hospital et al: 95-CU-84058
4 Nourhaghighi v. Ontario Judicial Council et al: 96-CU-104952
5 Nourhaghighi v. Bell Canada et al; 96-CU-113026
6 Registrar, Abby Katz STARR (“Starr”), mailed the Per-Conference
Report of August 31, 2006 (“Report”) on Sept 8; and hearing date of October 26,
2006; on Sept 11; both by regular mails
7 Report of the Chair of the
Per-Review Conference, Ms. Katie OSBORNE (“Osborne”)
8 Mr.
Jordan GOLDBLATT, the Counsel on the record for Dr. Nguyen (“Goldblatt”)
9 Ms. Jan POND for the College (“Pond”)
CONFIDENTIAL 2
PART II
STATEMENT OF FACTS
3. I am Iranian
Muslim single parent citizen. In 1980 Iranian arrested Americans’ spies10;
since then there are enormous planed poisonous propaganda against us by certain media in Canada that the Crown 11 has improper influence on them 12.
Further, the Crown’s policy is clearly against Muslim and Iranian that
raised many protests and liability against the Crown inter alia I filed
application under the Extraordinary Remedies of the Criminal Code and Charter
against the Crown for obstructing my access to all courts’ services and
arbitrary dismissing all my files. Justice Hamilton of Superior Court of
Justice scheduled November 14, 2006 for per hearing. In my reply I must relay
in this file as the Crown submitted Ducharme Order that was related to moulds
in my Condo 13.
M1-M8
contains my complaints and few evidence against Nguyen;
M4-M7&M32-M35
are photos of moulds.
M29-third
para: …several times I complained against toxic mould and having breathing
problems. Nguyen asked me to find the name of mould and report to him…Nguyen
said Stachybotrys do not grown in house and drywall, it grown on plastic.
M33:Expert
report is contrary to Nguyen; photographs 1&2 Obvious visible mould on gypsum
board ceiling. Nguyen criticized me for taking action…In last few
years, I made constant complaints for having breathing problems, allergies, and
headache...maliciously did not send me to any skin and respiratory specialists
M29-second
para. He is suing his Condo corporation
On October 19, 2004 the Court made Order that the Condo
must investigate the issue of heath hazard and sat February 23, 2005 for
hearing that the Court made Order against the Condo for repair that again the
Condo disobeyed Orders:
M25-Nov
29/04 Patient is agitated, shouted that the mold
has been identified as very toxic…accused me of conspiracy with his Condo
management by delay his treatment and referral. He calls me “ a criminal” and
stated he will complain to the College.
SUBMISSION RECORD First page of Notice of Application SM31-06 13;
p. 1
10 444
Days imprisonments of American’s spies, arrested at the US Embassy in Tehran;
the end of
diplomatic
relationship with US; American’s military attacks and shutting down the Iranian
Airbus with missiles killing over 300 passengers; Supporting Iraq in war
against Iran and encouraging
Iraq in explosions of
several chemical bombs in Iran causing billions dollars damages to Iranian
11 The
Crown defendants in my actions: The Federal, Ontario and Quebec Governments,
12 Defendant
Toronto Star, Action 96-CU-104952; Defendant Globe &Mail, Action
96-CU-113026
13 Application
Record of Respondent Her Majesty the Queen (“Ontario”) filed by the Contemnors
Crown’s Lawyers W. LIGHTFOOT; H. MACKAY; file SM 31-06
HPARB/ CONFIDENTIAL/
File # 5615 3
4. I was the
systematic inspector 14. I discovered ample corruptions of the Crown
and the Courts 3, 4, 5, 13, 15and acted duly. Police 16
targeted me with malice, torture17, and felonies 18
causing serious injuries like fractures of bones 19 to me requiring
services by the medical professions, obstructing my access to the hospitals 3,
4 and medications. However, the Committee did not uphold my complaints as
the College’s investigations was dishonest and biased, the prosecutions was
corrupt and made in my absentia 3, 4, 5.
In April 2004 I filed a judicial review
application against SIRC & CSIS 16 that a writ of mandamus be
issued against SIRC to investigate my complaint against CSIS, in which SIRC
without proper investigation closed my file. The Respondent, the Attorney
General of Canada admitted to my submissions that I had rights to be present
before SIRC that on January 31, 2005, Justice LEMIEUX made Order against
SIRC. Therefore, I got five days hearing before SIRC Chair Gary FILMON who
uphold my complaint, in part, and made Order that CSIS must apologize from
me.
In June 2004 my kitchen’s ceiling collapsed due to
toxic moulds and until June 2005 my Condo refused to repair due to the Crown
and Police interference as they want make me busy with ‘moulds’ that I could
NOT focus on my research and presentation before
LEMIEUX & FILMON.
LEMIEUX & FILMON.
In August 2004 I filed application against Condo
for disobeying Orders to repair water damages that ended to growth of toxic
moulds. Justice Ducharme made Order for cross- examinations of affidavits be
commenced of December 1, 2004.
In November 29, 2004 Nguyen had another misconduct
with me to increase my stress and frustration during the most important step of
my legal proceedings. M25-Nov 29/04
5. On December 13, 2004 I served my complaint
against Nguyen to the College.
I called several times got
no proper answer. I objected to intake Officers for not sending reply to me. It
was very unusual. I served that the College did not deny the receipt. There is
nothing in the record that indicates the initial correspondence send to me.
14 In
the Iranian Air Force, as a second job to my main profession senior fighter
& transport pilot
15 The
Courts: The Federal Court, the Ontario Courts, the Quebec Courts; Federal Court
of Appeal, Court of Appeal for Ontario, Court of Appeal for Quebec and the
Supreme Court of Canada
16 POLICE: Federal
Police: the Canadian Royal Mounted Police (“RCMP”); the Canadian
Security Intelligent Service (“CSIS”); Provincial Police: the Ontario
Provincial Police (“OPP”); the Quebec Provincial Police (“QPP”) Municipal
Police: Montreal Police, Ottawa Police, Quebec City Police, Toronto Police et
al (“POLICE”)
17 Ontario
[Toronto Police Offenders] v. Nourhaghighi; Judgment of
Justice Cadsby
18 Forgery & Fraud in Motor Vehicle Accident (“MVA”) Report by Toronto
Police; RE Justice Bigelow
19 Fracture of my Rib # 8 is admitted by St. Michael Hospital; after
denial of Toronto Hospital and Mount Sinai Hospital, when Police agents lost me
in their interception due my advance tactics
CONFIDENTIAL 4
6. On
January 13, 2005 I wrote to the Board that the College did not reply to my
complaint. Starr replied: Board has no power to require the College to acknowledge
or reply to you regarding your complaint -these letters are not in the
record. Few weeks after, I got a letter from Fewer asking me to call him-M9.
While I was stressed in my prosecution against Condo, yet several times I
called and left messages. I did not get any reply. I complained to the Board
against the College-M12.
SUBMISSIONS RECORD My letter Jan 13/05, p.2; HPARB letter Jan
14/05, p,3
7. On April
14, 2005 the Deputy Registrar, James TERRY sent a copy of my letter to the
College and asked five following questions-M10-11.
1)
What is history of investigation?
2)
Specifically, what investigatory steps, if any, remain to be either commenced
or completed?
3)
What, if any, required information or documentation remains outstanding?
Specifically, what steps will the College
be talking to secure the outstanding required information?
4)
What is the matter likely to be considered by the Complaints Committee?
5)
What is the Complaints Committee’s explanation for delay in the disposition of
this matter?
There is no evidence that the College comply with the Deputy
Registrar’s instructions. However, on April 25, 2005, the College-Truster
fraudulently alleged that it was unclear whether the complainant
wished to proceed-M54. The Board could ask that: Whether Inspector Fewer
took any step, by mean of follow up letter, to make unclear issue clear?
I intentionally did not
provide a telephone number that due to the confidentiality of the issue to get
chance to talk face to face with the inspector, as its is procedure. Further,
Fewer did not send copy of Nguyen’s reply to me-M15-17 for my reply to it; nor
informed me that whether got my medical record, or whether medical
record is complete and without my notice, forwarded its incomplete investigation
to the Committee.
I had rights to a complete
presentation before the Committee, as I have same rights before the Board. The
Committee erred in fact that the investigation before it was complete, did not
examine with honestly and impartiality the investigator’s letters on the
record-M52-56 inter alia did not asked for the investigator’s notes for
letter January 25, 2005, did not demand answer for letter April 21, 2005
that why I should be obligated to send consent within 10 days, did not examine letter April 25, 2005 to determine that the actions of the
investigator and the Committee Support Manager were constructive.
HPARB/ CONFIDENTIAL/
File # 5615 5
8. On April 27, 2005, Chair Condos rendered Decision &
Reasons against the College that was omitted by the investigator Fewer in
records before the Committee, and is not disclosed to disclosure too. Condos
did not give a chance of reply to me and arbitrary, as usual, relied on the
College reply; yet, confirming my facts in last paragraph that: While the
College might well have been more proactive in ascertaining Major
Nourhaghighi’s intentions…in which these reasons shall be weighted to the
professional negligence against the Investigator Fewer, and the College.
SUBMISSIONS RECORD Condos’ Decision & Reasons; p. 4
9. On April 28, 2005, the Court made Order against my Condo’s property manger to clean the mould, contrary to Nguyen’s will and action in obstruction of justice that I b able to have proper medical record indicating injuries that I suffered due to toxic moulds.
The Crown and Police
interference with normal business of citizens and my Condo has ended to over
$500.000 legal expenses my Condo and me, where large numbers of owners are very
low income like me, and protesting against the board of directors calling them
names, thieves, cheaters etc. The Crown and Police encouraged the Condo to
appeal against the Costs Order of Justice Pitt and claim more than $100.000.00
from me. I represent myself in the Ontario Court of Appeal, and again, I got
judgments against the dishonest, biased board of directors. This was additional
success
In obtaining Orders against the Crown’s parties inter
alia I got Judgments by representing myself at trials against defence
lawyers of the Canadian Imperial Bank of Commerce, the Bank of Nova
Scotia, and several small corporations of accused of ‘wrongful dismissal’
due to improper influence of the Crown.
SUBMISSIONS RECORD Notice of Application; 04-cu-273627CM p.6
Home Inspector Heath Hazard Repot p.10
Endorsement Court of Appeal for Ontario
v. Condo p.11
Order
of Justice Pitt v. Condo & Caber p.13
Order of Court of Appeal for Ontario v.
Condo & Caber p.14
Order of Federal Court Order v.
SIRC & CSIS p.15 Major Nourhaghighi v.
SIRC & CSIS T-762-04
RE:
Paragraph 4 of these submissions
My
Letter to Owners of Condo Re: Toxic Mould p.16
RE:
Nguyen & College Violated Public Interests Issue
HPARB/ CONFIDENTIAL/
Nguyen File # 5615 5
10. Since I was child, I had periodical medical examinations. I
became pilot, and senior pilot that continue my periodical medical examinations
in Iran, Pakistan, German and Canada. I had relatives who were physicians.
Therefore I have personal knowledge and experiences of the physicians’
professional conduct, and the physicians’ standards of practice. I
used the said parameters in filing my complaint against Nguyen’s sexual assault
during prostate test.-M2:last para. This was an important issue that I had
rights to sit and discuss with the investigator face to face to provide the
particulars.
11. The Committee in page 2, at subparagraph title superscript
“1”, line 9 is referring to my letter dated May 9 and the fact that I
wrote: the “College’s Investigator Fraud” adding: “Mr. Nourhaghighi had
written to HPARB…asserting that the College was not acting with honestly and
good faith” I was unable to find the said letter-May 9, in the
College’s record, in the Board’s disclosure and in my own personal record. This letter must be served and filed by the
College, at least three weeks before the hearing.
12. While Nguyen for years denying issuing a referral to
specialists. However, in December 2004 I changed my family doctor, and have got
ample referrals. This fact is not contradictory to the facts that the Crown and
Police did not interfered with my medical care and Nguyen. My complaint against
Nguyen, Orders against SIRC and Condo and angers of owners in my Condo were
‘Red Lights’ to the Crown and Police to cease their crimes against me, for a
while. All learn judges and lawyers in Canada are fully aware that no one in
Canada has more knowledge and master evidence of the crimes of the Crown. My
new family physician, in addition to ample referrals even wrote a notice to my
Condo’s property manager to provide me with accommodations before clearing the
mould. Soon, for the first time I discovered that I have very serious heath
problems and must consider many factors in my life that Nguyen never has given
chance to a specialist to discover it.
SUBMISSIONS RECORD Notes of Dr. Soboloff MD to property manager p.16
CONFIDENTIAL 7
13. The College did not sent Nguyen’s reply to me. After reviewing
disclosure, I discovered more evidence against Nguyen that the Crown has used
to mislead CSIS & SIRC. I testified before SIRC that the ’Attorney General
of Ontario’ by forgery drafted false materials against me and asked CSIS to
signed and mislead the Minister of Citizenship then as a ‘federal information
against me. All documents in this issue are marked SECRET. At this time I am
unable to disclose more facts in this issue.
PART III
POINTS IN ISSUE
14. The issue is:
A. Whether there were complete Records before the Committee?
A. Whether there were complete Records before the Committee?
and if
the answer is the affirmative; then,
B. Whether there is a complete ‘Respecting
Disclosure of Records’ before the Board that satisfies s.31 of the Regulated
Heath Processions Act, 1991 (“RHPA”)?
and if
the answer is the affirmative; then,
C. Whether two days short notice for presentation
of submissions before the Board for a
self counsel complainant constitute a fair and reasonable notice?
and if
the answer is the affirmative; then,
D. Whether there is evidence to proof that
the investigation was complete, there was no bias on the part of the College
and Investigator, in particular where sexual assault and public interest
issue-Moulds were parts of complaints and the Committee made a fair and
reasonable decision in my absentia?
CONFIDENTIAL 8
PART IV
LAW & ARGUMENTS
15. It is respectfully submitted that the
answers A, B, & C to the per-review hearing are the negatives; and October
26, 2006 is a pre mature for fair reviewing of this case.
I
admit to the fact that I erred in telephone conference by submitting that the
records are complete; as it has never happened in all my reviews that the
College files a defective disclosure. Further, the telephone conference was a
new process for me that I have never witnesses in HPARB.
16. In any event that the Board provides the
affirmatives answers to questions A, B, & C, I will present my argument of
law orally, as it is scheduled; and in summarily I would submit that it is
instructed by the Health Professions Procedural Code, 51. (1)
A
panel shall find that a member has committed an act of professional misconduct
if, …
(b.1) the member has sexually abused a patient;
(b.1) the member has sexually abused a patient;
(c)
the member has committed an act of professional misconduct as defined on the
regulations. 1991, c.18, Sched. 2, s. 51(1); 1993, c.37, s..14(1).
17. Further, the sexual abuse of a patient is
defined as:
(a) sexual intercourse or other forms of physical sexual relations between the member and the patient,
(a) sexual intercourse or other forms of physical sexual relations between the member and the patient,
(b)
touching, of a sexual nature, of the patient by the member, or
(c )
behaviour or remarks of a sexual nature by the member towards the patient.
1993, c. 37, s.4.
18. It is submitted that bias is a major factor for review of the
Committee’s decisions on its merits, and to accomplish it the Board must be
lead with all ‘information and records’ that the College and investigator had,
but did not forwarded to the Committee in first instant before the Committee
making its decision. And f the Committee have seen all my documents disclosed
with my letter dated May 9, 2005, then I have right
CONFIDENTIAL 9
that the Board those documents
too. In sexual assault the faith of prosecutor is playing a main role. In case
of “Discipline September/October 1993; Dr, Roger Edward Morgan; Sudbury” it is
been clearly instructed that the College has duty to prosecute properly. We all
know by experience that when the prosecutor has interests, or is biased, or
his/her investigation is not complete, never a fair judgment would be
rendered.
19. Furthermore, I would rely in the Heath
professions Act, the Quality of Care Information Protection Act,
2004, the Regulated Heath Professional Act, 1991
The Personal Heath Information Act, 2004; at section 72-1 instructed that A person is guilty of an offence if the person, willfully collects uses or discloses personal heath information in contravention of this Act or its regulations.
The Personal Heath Information Act, 2004; at section 72-1 instructed that A person is guilty of an offence if the person, willfully collects uses or discloses personal heath information in contravention of this Act or its regulations.
PART V
ORDER REQUESTED
20. I
request that the hearing of this file sat for October 26, 2006 be adjourned
until
a complete disclosure served to me and
file duly.
In alternative, I request if these
submissions have sufficient weight to satisfy the Board that the Committee has
made its decision upon inadequate investigations forwarded by the
investigator Fewer, return my complaint to the Committee and makes order that,
in accordance with law, the Committee commence new investigation in such I get
chance of ‘personal appearance’ before the Committee and testify under the Oath
against Nguyen. In this case, taxpayers
are saving a day of hearing.
In further alternative, the Board reviews the Committee decisions in accordance with law.
In further alternative, the Board reviews the Committee decisions in accordance with law.
ALL OF WHICH IS
RESPECTFULLY SUBMITTED
Dated in Toronto, this September 29,
2006 MAJOR KEYVAN NOURHAGHIGHI
Cases: Committee Decision found that Dr.
Lam Van Nguyen had committed an act of of professional misconduct, guilty of
sexual assault; suspension for six month.
Exact case of mine
Discipline September/October 1993
Dr, Roger Edward Morgan; Sudbury: This
case reported to the professional as case #18 in March 1991 Report of the
Discipline Committee Proceedings. Dr. Bayang had been found guilty by the
Committee of charge of professional misconduct and of the allegation of
incompetence
Canada exercised independence strategy
with Iran and Muslim. As the result, the numbers of Iranian from few hundreds
increased to over two hundred thousand, and the numbers of Muslim increased to
over one million. We are having confidence that the Constitution Act,
1982 is fully protecting all of us. Nguyen’s actions and the College’s Decision
are outrageously dishonest and breaching ss. 1, 2, 6, 7, 8, 11, 12, 15 and 24
of the Charter
having all rights under the law and the Charter
to be served professionally. The service providers are obligated to consider
the law, the ethical code, and dignity of all citizens as the fundamentals of
the professional conduct, and the professional services.
All parties have as solved in the
telephone conference by all parties. Ms.
and the counsel for
September 29,
2006 SERVED
Abby
Katz Starr, Registrar Major
Keyvan Nourhaghighi
Health Professions
Appeal and Review Board (“Board”) 456-608
College Street
151 Bloor Street, West, 9th floor Toronto,
ON, M6G 4A3
Toronto,
ON, M5S 2T5
File
# 8615, Nourhaghighi
v. Nguyen
Enclosed
herewith is my “Submissions Record” in reply to your letters dated September 5
&11, 2006 sent by regular mail that I received on September 27.
Your
letter of September 5th mailed on September 8th and had
enclosure of Pre-Review Conference Report signed by Ms. Katie Osborne who sat
today as the last day for me to serving you with my “Submissions Record” that
addressing three main issues rose by Ms. Osborne:
a. Grounds for confidentiality of the hearing;
b. Fresh Evidence, and
a. Grounds for confidentiality of the hearing;
b. Fresh Evidence, and
c. My Submissions
I
had only two days to complete my “Submissions Record”. You are well aware that
this is not the first time that you, the Board and the Crown are prejudicing my
rights
Your
letter of September 11th informed me that the Board is going to
review my complaint on October 26, 2006, which is acceptable for me, and I will
attend in person.
All my hope is that the members of Board on October 26
not be selected from those who harmed me by their scandalous decisions in past.
MAJOR KEYVAN NOURHAGHIGHI
I shall mention that a judge
on October 2004 sat February 23, 2005 for hearing of my application for contempt
proceeding against the board of my condominium (“Condo”), when the
disobedience of the Orders by the Condo caused the growth of toxic moulds in
the ceiling of my kitchen.
For example for in Iran, Pakistan and
Germany for genital and prostate examinations, I saw always a medical assistant
beside physician who was performing the tests. I did not witness this safeguard
in Canada. However, I was told that some hospitals exercise this safeguard only
for women’s particular examinations. Canadian giving too much weight for sexual
complaints made by women; and do not give any weight to men’s similar
complaints
11.
SUBMISSIONS RECORD Notice of Application; 04-cu-273627CM p.6
1. In 1995 and 1996 I filed three actions against the College
for not prosecuting the physicians who had disgraceful, dishonourable,
unprofessional conduct, professional misconduct, failing to maintain the
standard of practice and contravening the Acts2, 3, 4.
As the result, the Crown and
Police defendants in my actions, encouraged to continue improper influence over
my medical services.
It is the Crown’s unlawful
customary practice to attack to the parties acting against it that they fail to
concentrate on their very limited time of presentations before judges.
SUBMISSIONS RECORD Notice of Application; 04-cu-273627CM p.6
19 Major Nourhaghighi v. the Security Intelligent
Review Committee (“SIRC”), CSIS and the Attorney General of Canada et al;
T-762-04; see Lemieux Order
while ample ‘trial judges’ after careful examinations
have made good judgments for me
The College1 is
defendant in my three pending actions 2, 3, 4 for not prosecuting my
complaints and other wrongdoings to cover up the crimes of the Crown
was satisfied that the College, willfully,
denied replying to me, and was rude to me in telephone conversations, to cause
me mental anguish in critical time of February 2005.
The Committee at M-9
indicates
5. On September 11, 2001 the US Government
alleged that Muslim attacked them. The Crown8, the Courts 9,
the federal 10, provincial 11, and municipal police 12
(“they”) used this opportunity and harshly attacked me and other Muslims inter
alia Arar1, Ahani1, Soursh1. They used Nguyen
as agent who abused his office and forwarded ample questions for discovery of
my skill, experience, believe, expression, religion, and information. Nguyen
searched my thought by entering into long political argument with me relating
to 9/11. Then, they forwarded ample outrageously dishonest fabricated
information against me to CSIS, RCMP and the Minister of Citizenship1
who suspended my landed status; forwarded the fabricated information to judges
and dismissed all my legal proceedings and complaints; intercepted everywhere
in Canada and US forcing me to return to Toronto; suspended my immigration
landed status, and planned to deport me from Canada as the threat to the
security of Canada under s.19 of the Citizenship Act & the Immigration
Act.
2 Arar
v. Canada, Ahani v. Canada, Soursh v. Canada
1 Nourhaghighi v. Minister of Citizenship T-768-03
2 S
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