NOTICE OF MOTION FOR THREE JUDGES TO REVIEW A SINGLE JUDGE RULE

NOTICE OF MOTION FOR THREE JUDGES TO REVIEW A SINGLE JUDGE RULE

 

 

 

 

Court File No. C64295


COURT OF APPEAL FOR ONTARIO

 

BETWEEN:

OVERSEA CHINESE FUND LIMITED PARTNERSHIP, WEIZHEN TANG & ASSOCIATES INC.,    WEIZHEN TANG CORP, WEIZHEN TANG

 -AND-

APPELLANTS

TOM TONG, RECEIVER FOR WINWINCAPITALMANAGEMENT, LLC, WINWIN CAPITAL LIMITED PARTNERSHIP, J.O.R. & ASSOCIATES, LLC, WINWIN CAPITAL

PARTNERS, LP, AND BLUEJAY INVESTMENT, LLC, D/B/A/ VINTAGE INTERNATIONAL INVESTMENT, LLC

-AND-

Respondents

SI YI QIU AND GUOSHENG WANG

 

NOTICE OF MOTION

Respondents

Weizhen Tang, Oversea Chinese Fund Limited Partnership

17 Silk Court Richmond Hill Ontario,

L4B 4A4

Tel: (416)886-8715  Self represented

 

NOTICE OF MOTION

I, Weizhen Tang , the appellants will make a motion to the Court of Appeal for Ontario on a date to be fixed by the registrar to be heard to set aside or vary the order of a judge Juriansz

J.A. of an appellate court under subsection 7 (5) or 21 (5) of the Courts of Justice Act made on Dec. 13, 2017 pursuant to R.R.O. 1990, Reg. 194, r. 61.16 (6); O. Reg. 82/17, s. 12 (3). , at 130 Queens Street West , Toronto M5H 2N5

 

□in writing under subrule 37.12.1 (1) because it is (insert one of on consent, unopposed or made without notice);

PROPOSED METHOD OF HEARING: The motion is to be heard (choose appropriate option)

□in writing as an opposed motion under subrule 37.12.1 (4); orally.

THE MOTION is for

  1. A panel review a single judge order and to set aside or vary the order of a judge Juriansz A. of an appellate court under subsection 7 (5) or 21 (5) of the Courts of Justice Act made on Dec. 13, 2017.
  2. Justice Juriansz A. knew the appellant could not win or succeed in the appeal without counsel and made the appellant and my limited partnership unrepresented and to lose the appeal or abandon and unreasonablly endorse the security of cost of $35,000 to the law firm, it is a conflict interest to enrich the law firm and law society.
  3. Justice Juriansz A. and the law firm use the law and justice for profit, their own commercial use.
  4. Appellant Apply to enforce relevant Constitution Act and Canadian charter of rights and freedoms section
  5. in alternative order Gowling WLG Canada LLP return all the money $300,000 stolen from our limited partnership to the partnership to retain counsel or lawyer to represent it in court.
  1. order to use remaining fund of $40,000 for the appellant to retain counsel and advance the

THE GROUNDS FOR THE MOTION ARE .

We had money of $440,000 from day one March 18, 2009 since the so-called fraud investigation, the judges of the commercial court in Toronto and the law firm, Gowling WLG Canada LLP operated on collusion basis and stole our money from our limited partnership and from investors without authorization from investors and the owner of the asset .

 

  1. Since March 18, 2009, Ontario Securities Commissions (OSC) started investigation and froze our accounts, every lawyer and judge took our money from our business accounts and from my investors and deprivation of our legal rights and disable our defense before investigation complete ans trial
  2. The Oversea Chinese Fund Limited Partnership is Ontario legal entity and has its rights and obligation. OSC called somebody fraud and gave the court and judges the rights to take away investors’ money and asset without due process and trial?
  3. Why Ontario government and OSC and the court of Ontario, the superior court of justice unlawfully froze the money and took for themselves before conclusion of investigation complete and
  4. Oversea Chinese Fund Limited Partnership had $440,000 under Gowling WLG Canada LLP under the control and $300,000 under the control of a trust account of Bennett Jones LLP, its fund never has been used to represent its own legal affairs and rights
  5. Oversea Chinese Fund Limited Partnership was forced to be unrepresented and made the partnership and investors lost everything in its accounts because of un-representation
  6. The president and general partner, the limited partners have no access to the Oversea Chinese Fund Limited Partnership account, only the lawyer and the court have
  7. Oversea Chinese Fund Limited Partnership has done nothing wrong and there is no violation or conviction
  8. The Canadian charter of rights and freedoms Section 7 of the Canadian Charter of Rights and Freedoms is a constitutional provision that protects an individual’s autonomy and personal legal rights from actions of the government in There are three types of protection within the section, namely the right to life, liberty, and security of the person.

THE FOLLOWING DOCUMENTARY EVIDENCE will be used at the hearing of the motion: the appeal book, exhibit book and factum and book of authorities have been filed to the court of appeal Date: Dec. 15, 2017

Signature:

Weizhen Tang, the president and general partner and limited partner of Oversea Chinese Fund Limited Partnership

 

TO:

GOWLING WLG (CANADA) LLP

Barristers &Solicitors

1 First Canadian Place, Suite 1600 I00 King StreetWest Toronto, ON MSX !GS

Alex Zavaglia and

LSUC No. 57622J

Tanya Rocca

LSUCNo.

Tel:416.369.7298

 

AND TO:

ONTARIO SECURITIES COMMISSION

Joint Serious Offences Team

20 Queen Street West, 22nd Floor Toronto, Ontario M5H 3S8 HUGH CRAIG

LSUCNo 4l650S Tel: (416) 593-8259

Fax: (416) 593-2319

hcraig@osc.gov .on.ca Senior Litigation Counsel CARLO ROSSI

LSUC No 59054T Tel: (416) 204-8987

Fax: (416) 593-2319

crossi@osc.gov.on.ca Litigation Counsel

Counsel for the Ontario Securities Commissions

 

Court File No.: C64295

 

TOM TONG, RECEIVER FOR WINWIN CAPITAL MANAGEMENT, LLC, WINWIN CAPITAL LIMITED PARTNERSHIP, J.O.R. & ASSOCIATES, LLS, WINWIN CAPITAL PARTNERS, LP, AND BLUEJAY INVESTMENT, LLC, D/B/A/ VINTAGE INTERNATIONAL INVESTMENT, LLC

 

– and –

 

OVERSEA CHINESE FUND LIMITED PARTNERSHIP, WEIZHEN TANG & ASSOCIATES INC., WEIZHEN TANG CORP. AND WEIZHEN TANG

 

Appellants/ Respodents

 

– and –

 

SI YI QIU AND GUOSHENG WANG

 

Respondents

 

 

Respondents/ Applicants

 

COURT OF APPEAL FOR ONTARIO

 

 

 

 

NOTICE OF MOTION

 

 

 

Weizhen Tang, Oversea Chinese Fund Limited Partnership

 

17 Silk Court Richmond Hill Ontario, L4B 4A4

 

Tel: (416)886-8715

Email: weizhentang@gmail.com Self represented

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