Barristers &Solicitors
1 FirstCanadianPlace, Suite 1600
I00King Street West
Toronto, ON MSX !GS

Alex Zavaglia and
LSUC No. 57622J

Tanya Rocca

Barristers & Solicitors
2204 Queen Street East, Suite 4
Toronto, ON M4E1E7
Adam Ezer
LSUC No. 54738F
Tel: 416.926.1317
Fax: 416.926.0940
Lawyers for the Respondents,
Si Yi Qiu and Guosheng Wang


ONT ARIO SECURITIES COMMISSION Joint Serious Offences Team 20 Queen Street West, 22nd Floor
Toronto, Ontario M5H 3S8
LSUCNo 4l650S
Tel: (416) 593-8259
Fax: (416) 593-2319
Senior Litigation Cotmsel
LSUC No 59054T
Tel: (416) 204-8987
Fax: (416) 593-2319
Litigation Counsel
Counsel for the Ontario Securities Commissions

The motion moving parties, Weizhen Tang, Oversea Chinese Fund Limited Partnership, Weizhen Tang and Associates Inc., Weizhen Tang Corp made a motion on on Friday, December 15, 2017 to a panel of judges to review a single judge’ endorsement on a day to be fixed and the Motion can be heard at the court of appeal for Ontario, Toronto, Ontario.

The moving parties have filed notice of appeal, appeal book, exhibit book, factum and book of authorities and The moving parties also successful perfected the appeal and scheduled or listed fro hearing on Monday, February 26, 2018.

The moving parties believe that The respondents , Gowling WLG Canada LLP committed a crime of fraud over $5000, stole our frozen funds of $350,000 of our investors and justices of Superior Court of Justice Ontario, Commercial list and justices of appeal court committed a collusion of stealing or robbery of money from the public and tax payers under the cover-up and name of justice.

The circumstances of the case was originally investigated by the Ontario Securities Commission. This included the OSC freeze approximately $400,000 under s.126 of the Securities Act (Ont.). The Applicant claimed an interest in $200,000 of that money. By Order of Justice Peppal the money seized was to be disbursed, pro rata, to the investors who had an interest in the money at the conclusion of the criminal proceeding (subject to further order of the Court).

The courts constantly took our money from our brokerage accounts and deprive our rights , repeatedly refused to appoint counsel pursuant to the Rowbotham application in the course of criminal court proceedings and appeals. We are forced to be self-represented or unrepresented and lost everything.

It is the Canadian constitutional rights for people and a corporation to be represented in the court at the time of investigation.

The authorities and the courts, the law firm freeze public funds and destroy public defence in order to enrich themselves and their institution and the law society, not for the interest of justice.

Without the aid of counsel to assist, the Applicants have made various submissions to this Court at various times seeking to revisit orders earlier made and seeking to make submissions on the basis of issues that would not amount to errors warranting this Court’s intervention. It is important that justice be seen to be done in this case. It is also important that whatever arguable grounds that might exist for appealing the judgment of be properly presented to the Court in a way that will allow the Court to properly adjudicate the issues.

It is our intention not to act in person and not to be UN-represented

It is also our intention to stay proceeding until the time that we could be represented by counsels in the court of appeal for Ontario if granted.
Dated on Jan. 30, 2018

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