PRODUCTION DEMAND: The following exhibits are referenced but NOT YET PRESENT. These gaps support preservation orders and FOI/ATIP demands.

PRODUCTION GAPS

Missing Exhibits Required for Court-Safe Compliance

Honourable Mentions: The Applicant respectfully records honourable mentions for Lucy Ceylan, Ceylan, and the family, acknowledging Lucy's persistence, strength, and sustained efforts, including her efforts relating to the death of her twin brother.

4 Production Gaps Identified

These exhibits are referenced in the master index but not yet present with verifiable URLs.

COURT_SAFE_MODE Impact

4 Smoking Guns Affected

GAP-001

McFadden Email Original

⚠️ MISSING
Description Sgt. Leah McFadden email to Francesco Longo
Date November 8, 2025, 7:03 PM
Format Required .eml with native headers (NOT forwarded/screenshot)
Source Francesco Longo local email storage
Smoking Gun #16 (McFadden Retaliation)

Key Content (From Index — NOT VERIFIED)

  • • From: [email protected]
  • • Subject: Re: Compliance - Evidence Package for Crown Attorneys Dale & Krainz - Case #21-845
  • • Admissions: "potential criminal harassment matter"; "I declined to do so"; "No active matter before courts"

Action Required

  1. Export original .eml from email client (with full headers)
  2. Upload to Hub
  3. Generate SHA-256 hash
  4. Update Exhibit Index with URL
GAP-002

ACSF.pdf (Attorney Crown Screening Form)

⚠️ MISSING
Description Attorney Crown Screening Form for Case #21-845
Format Required .pdf (original from disclosure)
Source Ontario Digital Disclosure Portal (SCOPE ID 1012001)
Smoking Gun #18 (Unsigned ACSF + Decoded Occurrence)

Key Assertion (From Index — NOT VERIFIED)

  • • ACSF allegedly has NO SIGNATURE
  • • 52-month prosecution without valid Crown authorization
  • • This is the "smoking gun" for ultra vires prosecution

Action Required

  1. Access: https://www.digitaldisclosure.mag.gov.on.ca/
  2. Navigate to SCOPE ID 1012001
  3. Download ACSF.pdf
  4. Upload to Hub
  5. Generate SHA-256 hash
GAP-003

Digital Disclosure Portal Screenshots

⚠️ MISSING
Description Screenshots showing SCOPE ID 1012001 active after dismissal
Format Required .png or .pdf (timestamped)
Source Ontario Digital Disclosure Portal
Smoking Gun #17 (SCOPE ID 1012001 Surveillance)

Key Assertion (From Index — NOT VERIFIED)

  • • SCOPE ID 1012001 remains active AFTER case dismissed (Sept 15, 2025)
  • • Portal shows Occurrence # but NO Information #, NO Court File #
  • • Indicates ongoing surveillance of dismissed case

Action Required

  1. Access: https://www.digitaldisclosure.mag.gov.on.ca/
  2. Take timestamped screenshot showing: SCOPE ID 1012001 status, available/missing document fields, date/time of access
  3. Upload to Hub
  4. Generate SHA-256 hash
GAP-004

Audio Originals (.mp3/.m4a)

⚠️ MISSING
Description All original audio recordings referenced in Master Index
Format Required ZIP archive + manifest (CSV/JSON)
Source Francesco Longo / Lucy Ceylan local storage
Count 87+ files

Key Files (From Index — NOT VERIFIED)

  • • $$$MyCallWRayHamlin.mp3
  • • Call2WPSofficerDan...mp3
  • • LucySpkgwOfficerRoland#20671.mp3
  • • call2LAWSOCIETYABOUTMARYNOLAN.mp3
  • • + 80 additional recordings

Action Required

  1. Collect all .mp3/.m4a files from local storage
  2. Create manifest with: Filename, Date recorded, Duration, SHA-256 hash, Key content/quote
  3. Package as single ZIP
  4. Upload to Hub
  5. Update Exhibit Index with URLs

COURT_SAFE_MODE IMPACT

Until these exhibits are produced, the following smoking guns cannot be displayed under COURT_SAFE_MODE:

Smoking Gun Gap(s) Current Status
#16 (McFadden Retaliation) GAP-001 Assertions HIDDEN
#17 (SCOPE ID Surveillance) GAP-002, GAP-003 Assertions HIDDEN
#18 (Unsigned ACSF) GAP-002 Assertions HIDDEN
#19 (87 Agency Coordination) GAP-004 Assertions HIDDEN

Smoking Guns #13, #14 remain FULLY VERIFIED — breach .eml and .jpg exhibits present.

RECOMMENDED DEADLINE

Produce all missing exhibits within 48 hours to enable: