Court File. No.

CV15-21840
ONTARIO
SUPERIOR COURT OF JUSTICE

BETWEEN
EDY HADDAD
Plaintiff
and

THE CORPORATION OF THE CITY OF WINDSOR

HELGA ELIZABETH REIDEL,
EDGAR (EDDIE) FRANCIS, and SEBASTIAN PIRRONE
Defendants
NOTICE OF ACTION
TO THE DEFENDANT
A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiff. The claim
made against you is set out in the statement of claim served with the notice of action.
IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must
prepare a statement of defence in Form18A prescribed by the Rules of Civil Procedure, serve it on the
plaintiff' lawyers or, where the plaintiff does not have a lawyer, serve it on the plaintiff, and file it,
with proof of service, in this court office, WITHIN TWENTY DAYS after this statement of claim is
served on you, if you are served in Ontario.
If you are served in another province or territory of Canada or in the-United States of America,
the period for serving and filing your statement of defence is forty days. If you are served' outside Canada
and the United States of America, the period is sixty days.
Instead of serving and Filing a Statement of Defence, you may serve and file a notice of intent to
defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to ten more days
within which to serve and file your statement of defence.
IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN
YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH TO DEFEND
THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID MAY BE
AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.

IF YOU PAY THE PLANTIFS CLAIM, AND $2,500.00 for costs, within the time for serving filling
your statement of defence, you may move to have this proceeding dismissed by the court. If you believe
the amount is excessive, you may pay the plaintiffs claim and $400 for cost and have the cost assessed by
the court.
TAKE NOTICE THIS ACTION WILL AUTOMATICALLY BE DISMISSED if it has not been set
down for trial or terminated by any means within five years after the action was commenced unless
otherwise ordered by the court.
February 4 , 2015

Issued by:

.
Registrar

TO:

Superior Court of Justice

245 Windsor Ave, Windsor, ON N9A 1J2
THE CORPORATION OF THE CITY OF WINDSOR
Attention City Clerks
350 City Hall Square
Windsor, ON N9A 6S1
HELGA ELIZABETH REIDEL
4948 Grand Blvd
Windsor ON N8T 3K9
EDGAR (EDDIE) FRANCIS
3715 Huntington Ave,
Windsor, ON N9E 3N4
SEBASTIAN PIRRONE
400 CITY HALL SQAURE E
Windsor, ON, N9A 7K6

`
The Plaintiffs Claim is for:
Damages for causing defamation and human rights violations against the Corporation of the City of
Windsor.
Media coverage dated September the 6th, 2012, February the 6th, 2013, and May the 15th, 2013. It was
stated that the Plaintiff was causing a disturbance and being disruptive in City Hall. The news coverage
conveyed the meaning that the plaintiff was guilty of causing a disturbance, and was kept off property
based on exaggerated and untruthful claims. The news coverage stated and was intended to convey the
meaning that the plaintiff was responsible and party to disturbing City Hall meetings based on unruly and
disturbing behaviour at city hall. The news media coverage as a result of the City of Windsor actions
tarnished the Plaintiffs reputation.
Damages for Human Rights Violations, as a result of the Plaintiff Being banned and removed from City
Hall by trespass notice, the plaintiff for over 3 years was not permitted to access freely any social
services, run for office, or participate any social activity or social advocacy at city hall. The permanent
ban, unreasonably limited the Plaintiffs constitutionally-protected freedoms of expression, and democratic
participation, as well as his ability access government services located on the premises. The Citys action

was found to be unconstitutional and the ban was rescinded on February 20th, 2013. The ban was a
violation which had been imposed without just reason causing irreparable harm to the Plaintiff.
Date: February 4, 2015
Edy Haddad
2669 Langlois Court
Windsor ON, N8X4V7

CV- 15 -21840

ONTARIO
SUPERIOR COURT OF JUSTICE

BETWEEN:

EDY HADDAD
Plaintiff
And
THE CORPORATION OF THE CITY OF WINDSOR
HELGA REIDEL, EDGAR (EDDIE) FRANCIS,
and SEBASTIAN PIRRONE

Defendant

STATEMENT OF CLAIM
Notice of Action Issued on February 4th, 2015
1. THE CLAIMS:
a) Damages in the estimated amount of $2,000,000;
b) Punitive damages in the amount of $2,000,000;
c) Prejudgement and post-judgment interest in accordance with Courts of Justice Act, R.S.O, 1990,
C.43;
d) His cost on substantial indemnity basis.
e) Such Further and other relief this Honourable Court deems just.

2. IF YOU PAY THE PLANTIFS CLAIM, AND $2,500.00 for costs, within the time for serving
filling your statement of defence, you may move to have this proceeding dismissed by the court.
If you believe the amount is excessive, you may pay the plaintiffs claim and $400 for cost and
have the cost assessed by the court.
3. TAKE NOTICE THIS ACTION WILL AUTOMATICALLY BE DISMISSED if it has not been
set down for trial or terminated by any means within five years after the action was commenced
unless otherwise ordered by the court.

The Parties
4. The Plaintiff was on social assistance at the time for less than 1 month after leaving home due to
suffering from violence because of his sexual orientation. A student the semester prior. The
Plaintiff was also working part time at a local bar, and actively volunteering in the community as
Chair of the Downtown Needs to Succeed Coalition and helping with various charities and
groups.
5. The Defendants are or were employees or elected officials at time of the incident of the
Corporation of the City of Windsor, and all were involved in aiding and abetting the service of
the Trespass notice on the plaintiff.
6. HELGA REIDEL was the Chief Administrative Officer Of the Corporation of the City of
Windsor
7. EDGAR FRANCIS was the Mayor of the City of Windsor who also directed and exercised
authority over Wilkki, Reidel, and Pirrone
8. SEBASTIAN PIRRONE was the Site Manager and Facilitator of City Hall.
The Trespass of the Plaintiff
9. On March 5th, 2009 the plaintiff was banned from City Hall after speaking as a Delegation, during
a City Council Meeting. He was stopped from speaking repeatedly by the Defendant Francis, and
was not allowed to continue giving his presentation.
10. Upon Returning to his seat, the Plaintiff was told to get his belongings and to go to the Hallway
by the Defendant Pirrone, The City Hall Site Manager, where two Windsor Police Officers were
waiting.
11. The Plaintiff was then told he must leave the building, without giving a reason to the why, and
then was told by the Defendant Pirrone once he exited the building that he is being banned, and to
not step foot on the property or he will be arrested.
12. The trespass notice was issued without giving clear reason as to why the plaintiff was being
banned, and was unreasonably placed as permanent, with no set time limit,
13. The plaintiff was given no form of appeal or method to overturn the ban.
The Concert by The Defendants at the City of Windsor
14. On or about 2009, each of the Defendants in concert with each other, the particulars of
which are known to the Defendants and partially unknown to the Plaintiff, and was
carried out in a clandestine manner.
15. The concert was to engage in unlawful acts in order to remove and to justify the

removal of the Plaintiff from City Hall premises by means of Trespass, in a manner
deemed by the Defendants to be in their political, personal, and/or financial benefit.
16. The concert was engaged in by the Defendants in a manner designed to injure the
reputation of the Plaintiff, or in the alternative in a manner that recklessly and callously
disregarded the interests of the Plaintiff.
17. The conduct of the Defendants, in engaging in this concerted effort, acting unlawfully
toward the Plaintiff, resulted in injury and damage to the Plaintiff; including the specific
injury and damage occasioned by his removal from City Hall and being barred from
accessing freely government services, and running for political office. The Plaintiff
suffered unjust public scrutiny and irreparable damages to his credibility.
18. The Defendants has concerted prior to the City Hall Meeting to have the Plaintiff
removed and trespassed regardless of his interests and human rights, and had called the
police prior to the beginning of the plaintiffs presentation to City Council concerting to
have him Trespassed.
19. The conduct of the Defendants has resulted in damage to the Plaintiff's reputation, his
career in politics' and public service, his ability to earn income, access government
services, his health, and his personal Well-being.
Defamation of the Plaintiff by the Corporation of City of Windsor
20. Statements made by the Defendant Reidel in the Windsor Star dated September 6th, 2012 implied
that the Plaintiff had committed a crime, and said police were consulted and then advised
municipal administrators that he shouldnt be on the premises.
21. Further Statements by Windsor Solicitor George Wilkki in the Windsor Star about the Plaintiff
described as over the top confrontational and disruptive the behaviour that first got Haddad
Banished
22. The statements made by the Citys Solicitor and the Defendant Reidel were untruthful, and
grossly exaggerated what happened that got the Plaintiff Banned. They never provided an actual
action or word that the Plaintiff said, or committed to deserve being Trespassed, defaming the
Plaintiff, and harming his reputation.
23. Other Statements by the Defendant Reidel on February 6th, 2013 included, We would have not
have issued the no-trespass order without good reason Further implying that the Plaintiff had
committed an undisclosed crime that caused him to be trespassed.
24. Further Statements in Metro News also on February 6th, 2013, contradicted the Defendant
Reidels previous statements, and admitting that the Plaintiff was banned not because of action at
City Hall, but due to undisclosed third party.
25. The Defendant Reidel is quoted in the media Windsor CAO Helga Reidel acknowledged that
Haddad had not been violent or threatening, but said his continuously disruptive behaviour
made some staff, as well as members of the media, feel uncomfortable. We dont do these
trespassing bans lightly, she said. But when we got the third party complaints, we decided to
something. Although Haddad often spoke before council, Reidel said his contributions seldom
pertained to anything on the agenda. In the times that he was a delegate, he wasnt speaking to
the issues that were before city council, she said. He simply wanted a voice on whatever issue
he wished, and that can disrupt a meeting.
26. Reidels Statements disregarded the Plaintiffs freedoms of expression, and further implied that
the members of the media were implicit in the defamation of the Plaintiff, so as to have him
trespassed so they did not have to report the Plaintiff.

27. The trespass defamed the Plaintiff by allowing the third party demand he be removed from City
Hall in secret, and having him banned indefinitely without public or the Plaintiffs knowledge as
to why he was trespassed.
28. Reidel also admitted that critiques of the Trespass Notices Valid as her statements made in the
Metro Times. Reidel sympathizes with the concerns raised by the Canadian Civil Liberties
Association and has informed the organization that Haddads prohibition has been lifted. Her
office is also looking to formalize the policy around bans, a process that will include investigating
whether indefinite bans are appropriate. Those critiques of our process were valid, she said.
We are looking at policy. We are looking at that particular issue and I think some added scrutiny
of the process will be a good thing.
29. Further Statements in regards to the Trespass policy on May 13th, 2013 in the Windsor Star, by
the Canadian Civil Liberties Association call the Permanent bans as a draconian measure which
cannot be justified in a free and democratic society
30. The City Of Windsor was forced to rescind their proposed By-Law after the CCLA (Canadian
Civil Liberties Association) sent a letter highlighting several concerns with the policy.
31. The trespass against the Plaintiff was rescinded on February 20th, 2013.
32. Pictures of the Plaintiff were also put up at various locations around City Hall, and City of
Windsor facilities urging all staff to call security or law enforcement officials if the Plaintiff came
on the property, or intended to access services.
33. This further damaged the Plaintiffs reputation, and grossly harmed and defamed the plaintiff.
34. In March of 2009, the Plaintiff was employed at the Boom Boom Room, Night Club in Windsor,
was fired due directly to incidents at City Hall.
35. In October of 2012, the Plaintiff was employed with Hard Knocks 365 Marketing Company, and
working at various locations throughout the province, was fired due directly to incidents at City
Hall.
36. In May of 2014, the Plaintiff was employed with Kognitive Marketing at various Canadian-Tire
locations, and was fired due directly to the incidents at City Hall.
The Plaintiffs Damages

37. By reason of the defamation and human rights violations the plaintiff suffered irreparable
damages to his credibility, character and reputation in a small city.
38. By reason of the media coverage as a result of the citys actions the plaintiff lost and will lose
lasting damages to his reputation in the estimate of $2,000,000.00
39. The conduct of the Defendants, which was malicious, unwarranted and unjust resulted and will
continue to result in the punitive and exemplary damages in the amount of $2,000,000.00 which
should be rewarded to the plaintiff.
Date: February 4th, 2015
Edy Haddad
2669 Langlois Court
Windsor ON
N8X 4V7
519 996 9388