III. DOCK TIMELINE (10 ENTRIES)
Nov 28, 2024
Political Criticism Posted
WHAT: Applicant posts criticism of police conduct online.
WHY IT MATTERS: Charter s.2(b) protected expression; establishes retaliation timeline.
EVIDENCE: LUCY MOTION.pdf
Dec 4, 2024
Arrest — 7 Days After Criticism
WHAT: Armin Ceylan arrested; charged under Criminal Code s.264.1 (uttering threats).
WHY IT MATTERS: Retaliation theory; abuse of process pathway (R. v. O'Connor).
EVIDENCE: LUCY MOTION.pdf
Dec 5, 2024
Bail Denial / Detention Begins
WHAT: Bail denied; Applicant remains in custody.
WHY IT MATTERS: Charter ss.9, 11(e); R. v. Antic, 2017 SCC 27.
EVIDENCE: LUCY MOTION.pdf
Ongoing
43+ Days Detained
WHAT: Motion asserts detention duration exceeds 43 days.
WHY IT MATTERS: Charter ss.9, 11(e); remedy framing for release.
EVIDENCE: LUCY MOTION.pdf (jail records pending)
2016–2026
Evidence Inventory (Proof Density)
WHAT: 70+ audio recordings, 165+ emails, 50+ images, 170+ PDFs.
WHY IT MATTERS: Demonstrates scale; supports systemic pattern.
EVIDENCE: LUCY MOTION.pdf
2016–2026
100+ Lawyers Declined Representation
WHAT: Motion asserts over 100 lawyers refused citing "conflicts of interest."
WHY IT MATTERS: R. v. Rowbotham; access to justice crisis.
EVIDENCE: Motion states; lawyer refusal list NOT PRODUCED
Legal Framework
Abuse of Process (O'Connor Test)
WHAT: Motion invokes abuse of process framework.
WHY IT MATTERS: R. v. O'Connor, [1995] 4 S.C.R. 411 — stay where state conduct shocks conscience.
EVIDENCE: LUCY MOTION.pdf + Book of Authorities
2004–2026
"Dynasty Pattern" — Criminal Organization Frame
WHAT: Motion frames 22-year pattern; 200+ perpetrators across 18 institutions.
WHY IT MATTERS: R. v. Venneri, 2012 SCC 33 (criminal organization concept).
EVIDENCE: LUCY MOTION.pdf
Jan 16, 2026
Brian Cobb Witness Testimony (Recording)
WHAT: Motion references witness testimony captured Jan 16, 2026.
WHY IT MATTERS: Alleged collusion / bad faith prosecution theory.
EVIDENCE: TRANSCRIPT-ONLY — AUDIO PENDING UPLOAD
Jan 22, 2026
Scheduled Hearing Date
WHAT: Motion references scheduled hearing.
WHY IT MATTERS: Informs urgency; ties to interim/bail relief.
EVIDENCE: LUCY MOTION.pdf
PROOF PANEL
Click a Dock entry to view proof details
PRIMARY PROOF DOCUMENT
LUCY MOTION.pdf
Full motion package including Notice of Motion, Affidavit, Constitutional Question, Book of Authorities, and Exhibit Book Summary.
VIEW MOTION (PDF)STATUS
VERIFIED EXHIBIT — PDF EXISTSWHY THIS MATTERS
The motion package is the primary evidentiary source for this viewer. All dock entries reference specific assertions within this document. The motion invokes R. v. O'Connor (abuse of process), R. v. Antic (bail), and R. v. Venneri (criminal organization).