| A Holocaust in Canada-The cruxificition of Glen P. Robbins Book 1 |
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Jan 28, 2009 |
| Glen P. Robbins writer and public opinion pollster is publishing all of the details relating to his multi-million dollar lawsuit against the government of British Columbia. Damning are the allegations in the case, which remains undefended by the BC government. Glen P. Robbins wants all readers to seriously consider the following truths as he now knows them to be. The problem with the legal system isn't just the system or access to justice. This has been the past mea culpa from top down for many years, whenever the 'system' is threatened. The problem is that too many people in the legal system are corrupt---in fact this Glen P. Robbins travesty, the Carrier Lumber case (where boxes of evidence was hidden away by bureaucrats in the BC Attorney General's Office)--in an attempt to cover their rear end while a British Columbians's business went into the drain)--the BC Rail raid on the legislature--lawyers filing phoney orders, phoney affidavits--no service of documents--no real effort by lawyers for clients---greed, laziness, sloth and the like. The problem with our legal system is not just about access and money--too many serious players are cheaters---corrupt--and they need to be outed. When you read this--case--I expect you will readily understand how sick and depraved some of these individuals are. I'm with Van Rassel--Don't Vote in this province--break its political back--bust its credibility (any that remains)--so that we can have are province back and be rid of the venomous rodents that currently control it. To this end--we will be dedicating an investigation into the lives of the top bureaucrats in government. Who are they--how much money do they make--what are their backgrounds? If you have any information you want to provide us in order to better understand some of these 'faceless' bureaucrats--please send it along to glen_robbins@email.com. As I write this we have received some new information about an island meeting involving players who may be linked to the BC Rail matter--we'll keep you posted. At no time in your life will you read a court document--developed in part prose--which so graphically exposes the protracted bad faith of a government, its workers, its lawyers. The intention of the government in this case goes far beyond taking a way a person's Charter Rights--it was a planned--deliberate attempt to ruin me--it worked--and it could happen to you. |
| ---Robbins says "The absolute conscious effort by government officials to concoct, contrive, and purposefully destroy my business, my name---to cause injury to my wife and children--and to remove every one of my Charter Rights including disbarring my attorney--including having lawyers induce perjured testimony--is in my opinion tantamount to a modern day Holocaust--the name normally associated with the killing of Gypsy's, Slavic people, disabled people, and in particular people of Jewish background--makes this case a modern day example of how the individual can be destroyed by government's whose power is left unchecked." Modern nations have worked tirelessly to reflect the importance of each individual in society--a move away from the aggressive power struggles of nation states---this case will reveal to readers--if they take the time to go through it--how each element of a corrupt system--if left unchallenged--if ignored--can result in what we have in BC today---unbridled power--unchecked--either by persons--or the media. We live in a dangerous land---Canada when you scrape away the phoney niceties of politeness and drill down on the reality of power--is not such a nice place. I would humbly ask that if you are reading this out of province (BC) or Canada--that you boycott coming here--don't endorse either the province or the country with your dollars. Don't subscribe to Holocaust Canada--force this country--as other democratic countries are forced to do--to acknowledge their sins against not only groups of people who have been badly treated--but individuals who are daily being sold a bill of goods that this nation if free. Nothing--absolutely nothing could be further from the truth. |
| Robbins--now regarded as one of the most accurate and controversial public opinion pollsters in the World--and who predicted the rise of Obama in the United States in January 08--10 months prior to President Obama's election--was previously an independent newspaper publisher and advocate of citizens rights-whose business and personal name he alleges were systematically destroyed by bureaucrats and others in the BC government between the years 1997 and 2001. This suit was filed just days before Gordon Campbell's first term--with a province from Glen P. Robbins MLA Christy Clark "to help". "You are a friend Glen--I will help" said Christy Clark in the midst of a dozen supporters after the BC Liberal win. Robbins has correspondence from former BC Attorney General Geoff Plant which suggests that he spent little time bothering with the matter and in fact--could be construed as a blow off. However, it is true that soon after Robbins litigation was first published the BC Human Rights Commission was dismantled--it is also true that the BC Human Rights Tribunal which posted the offensive information--with no reasonable basis for so doing (explainted well later in this lawsuit)--that Meta Tags were placed on the posting--to ensure that Glen P. Robbins, a man with no criminal record---and only one appearance in his life in a criminal court--for fighting---in the late 1980's--with a conditional discharge (two big men have a disagreement--one big man makes disparaging remark about a Robbins family member--one big man ends up unconcious--sometimes stuff happens. |
| Adds Robbins--"The government of B.C. in active collusion with the government of Canada--conciously used the judicial system--ensuring there was no defence on my behalf to come up with an ex parte Order which either declares, states or certainly gives the impression that I am a pedophile based on the testimony of a daughter of an old business partner--bitter over being Petitioned into Bankruptcy." This posting connects the name Glen P. Robbins with the word pedophile on Google for a period of one year. The evidence will show that the entire case was made up--did not stand up to technical legal scrutiny from the beginning--that there was ample evidence the woman involved were lying and that their lawyers--now Judges encouraged them to lie. Not all of the evidence is in the lawsuit--but enough to make any reader realize that--this was a contrived and ideological case driven by people in the legal community who in my personal opinion (protected under my right to free speech)--must be crazy--or mean--or messed up with too much power. |
| Robbins asserts that he "has no criminal record" and no history which would support this type of allegation." The removal of each and every one of my rights--based I believe primarily on the fact that I produced compelling news and threatened the status quo of the publishing business in the province and potentially across the country--and actions currently afoot to cause my wife and children further distress--are an attempt to stop me or to interfere with my ability to produce free speech." |
| Robbins concludes "The devil is in the details--and when these pleadings are published and names are published--people will immediately be able to bear witness to see that I was crucified by government---an example of a modern day Made in Canada Holocaust." |
| --Our story begins with Glen P. Robbins working as a consultant with Mitchell and Nadine Tannis--parents of 10 chilren-some from previous marriages--others from Lebanon--who are not biological children. |
| The Tannis family is big in the Catholic church at the time---family of 10 always sitting in the front pew--and Mitchell and Nadine are Godparents to Robbins daughter Veronica. Ironically, when Mitchell and Nadine Tannis are Petitioned into Bankruptcy by the BC Supreme Court--it falls to their daughter Jennifer to attempt to rescue the family name by conspiring with her girlfriends of many years a false harassment complaint against Robbins--for staring. Robbins managing partner is also accused of staring--and is not pursued on the allegation when it is discovered he is legally blind. It is also important to note that the Tannis's made accusations of sexual impropriety against a Priest of a Roman Catholic Church--when they were not able to 'get their way' on the Church's committees---the devil is in the details as I say. |
| The legal pleadings begin one third of the way through the document and are numbered as they are in the yet Undefended Claim by Robbins. Glen P. Robbins is referred to as the plaintiff in the case and when a defendant is referred to---their name is added. |
| 33. The plaintiff asserts that he was hired as an independent business consultant by the Defendants, Mitchell and Nadine Tannis on or about February of 1996 to assist them with their financial and business problems. |
| 34. The plaintiff asserts that from approximately February of 1996 until approximately September of 1996 the plaintiff was employed as an independent business consultant by The Tannis Group of Companies whose owners were the Defendants, Mitchell and Nadine Tannis. The plaintiff further asserts that the Defendants, Mitchell and Nadine Tannis wrote cheques payable to the plaintiff, which cheques were returned by the plaintiff's financial institution as non-negotiable due to non-sufficient funds, which cheques totalled an amount of $16,000 for consulting services performed by the plaintiff, which sum of money was never payed to the plaintiff. |
| 35. The plaintiff asserts that from approximately September of 1996 until approximately February of 1997 the plaintiff worked for Aurora-M.T. Publications which was a partnership between Mr. Brian Archer and the Defendant, Mitchell Tannis. The plaintiff further asserts that although his company, Calvary (sic) Publishing Corp was organized pursuant to the Companies Act of British Columbia in approximately September of 1996-- it did not possess its own independent banking account until approximately February of 1997 and possessed no assets of significant worth, and hence did not commence to do any business or to employ and persons until approximately February of 1997. |
| 36. The plaintiff asserts that he accepted an appointment to the position of Vice President of the Tannis Group of Companies in the Spring of 1996, only so that the plaintiff could legally assist and represent the Tannis Group of Companies in matters pertaining to the Petition of Bankruptcy proceedings against the Defendants, Mitchell and Nadine Tannis. The plaintiff further asserts that his efforts to assist the Defendants Mitchell and Nadine Tannis, for which efforts he was not paid, were decribed as "heroic" and "commendable" by the Honourable Madame Justice Loo of the Supreme Court of British Columbia. |
| 37. The plaintiff asserts that he acted as a contractor and/or employee, and was never an employer or manager in the Tannis Group of Companies, between approximately February of 1996, and approximately February of 1997. The plaintiff asserts that the Defendant, Mitchell Tannis, continued in his role as employer and manager of the Tannis Group of Companies during February of 1996, until his departure on or about February of 1997. |
| 38. The plaintiff asserts that the Defendants, Christopher Finding and the B.C. Human Rights Commission, erred when they failed to recognize the Defendants, Mitchell, Nadine and Jennifer Tannis as employers, and the Defendant Mitchell Tannis as the senior manager of the Tannis Group of Companies and that the Defendants, Mitchell, Nadine and Jennifer Tannis, and the Tannis Group of Companies should have been named as legal respondents to the sexual harassment complaints made by the Complainants, or in the alternative, the complainants should have been required to confine and limit their claims to the period of time commencing on or about February of 1997, as the majority of the complaints were alleged to have taken place while the plaintiff was neither an owner nor manager of the company for which the complainants worked, namely Tannis Printing Ltd. The plaintiff further asserts, that in such cases where workers and others are alleged to have sexually harassed co-workers or employees of a company, that the employer should be held liable for their employee' discriminatory acts, so long as the actions are work related-Canada (Treasury Board) v. Robichaud (1987), 8 C.H.R.R. D/4326 Supreme Court of Canada, and Shaw v Levac Supply Ltd. (1990), 14 C.H.R.R D/36 (Ontario Bd. Inq.). |
| 39. The plaintiff asserts that the Defendants, Mitchell Tannis, Nadine Tannis and Joseph Dauo, "..engaged in a kiting scheme to obtain the improper use of funds," as documented in The Supreme Court of British Columbia, Reasons for Judgement of the Honourable Madam Justice Loo, in which, Mitchell and Nadine Tannis were found to have engaged in cheque-kiting and fraud of the Canadian Imperial Bank of Commerce and VanCity Savings and Credit Union during on or about February of 1996, during which time an unauthorized overdraft of $72,467.09 was obtained. The plaintiff further asserts that the Defendants Mitchell Tannis and Joseph Dauo were prohibited from banking anywhere within the city limits of Greater Vancouver as a consequence of another cheque-kiting scheme and fraudulent activity perpretrated against The Fraser Valley Credit Union and The Bank of Montreal on or about July and August of 1996, during which time an estimated total of $125,000 in unauthorized overdraft was obtained. The plaintiff Glen P. Robbins further asserts that the Defendant Mitchell Tannis was previously discovered "kiting" cheques against another branch of the Canadian Imperial Bank of Commerce in 1990. |
| 40. The plaintiff asserts that many of the employees of the Tannis Group of Companies, received pay cheques which were subsequently returned to the employees with a status of Non-Sufficient Funds (N.S.F.), which pay cheques were from the Defendants, Mitchell and Nadine Tannis during the summer and fall of 1996, and in addition, many of the employees' deductions at source from their pay cheques were not remitted to various government agencies, and as a result of which, dozens of claims for lost wages and unpaid premiums and federal and provincial income taxes were filed by employees of the Tannis Group of Companies with the Employment Standards Branch of the B.C. Minister of Labour. The plaintiff further asserts that many of these employees have never received some or all of the wages owed to them by the Defendants, Mitchell and Nadine Tannis for work done while they were employed by the aforementioned Defendants. |
| 41. The plaintiff asserts that the Defendants Mitchell Tannis, Nadine Tannis, Joseph Dauo, and Jennifer Tannis defrauded the plaintiff when they induced him to purchase the assets of the Tannis Group of Companies by providing, through their bookkeeper Mrs. Shirley Ruthorford, with falsified, or in the alternative, inaccurate documents representing that the Tannis Group of Companies owned some $2,000,000 in assets combined with approximately $1,000,000 in liabilities. In fact, the plaintiff asserts that each of the defendants referred to herein were fully aware that any and all assets of the Tannis Group of Companies had in fact been hypothecated to a third party creditor, Coast Paper, which the plaintiff asserts has been confirmed by a Supreme Court of British Columbia Justice by way of petition and application under Rule 65. The plaintiff alleges that when on or about September of 1996 he and the Defendant, Jennifer Tannis agreed jointly to purchase the assets and assume the liabilities of the Tannis Group of Companies, the Defendant, Jennifer Tannis fully understood that she was entering into a business relationship with the plaintiff, and therefore the Defendant, Jennifer Tannis did co-conspire with the Defendants Mitchell Tannis, Nadine Tannis, and Joseph Dauo to knowingly defraud the plaintiff. |
| 42. The plaintiff asserts that on or about March 1, 1997, the plaintiff discovered that the Defendants Mitchell and Nadine Tannis were in breach of the agreements that they signed with the plaintiff on or about June 15, 1996 and on or about September 18, 1996 in which Calvary Publishing Corp agreed to acquire the assets and assume some of the liabilities of the Tannis Group of Companies due, the plaintiff alleges, to the fact that the aforementioned Defendants had provided all of their undertakings to a third pary on or about November 9, 1993. In response, the plaintiff asserts, that he and Brian Archer of A.T.I. Aurora Technologies Inc. filed suit against the aformentioned Defendants in the Supreme Court of B.C. on or about April 29, 1997, File No. C972494, for damages and lost business opportunities. The plaintiff asserts that the aforementioned Defendants filed their Appearances on this suit on June 12, 1997. The plaintiff further asserts that the Defendant Jennifer Tannis signed and dated her complaint filed with the Defendant, the B.C. Human Rights Commission on June 13, 1997, and the Defendant Glenda Lee filed her complaint on June 18, 1997, and the Defendant Laura Dato signed and dated her complaint on June 18, 1997. The plaintiff alleges that the timing of the filing of these initial sexual harassment complaints is a direct result of the response of the Tannis family to the law suit filed by the plaintiff. The plaintiff further alleges that the filing of these complaints was used as a tactic to intimidate and to seek revenge against the plaintiff, and to deflect the plaintiff's attention from the pursuit of the aforementioned lawsuit. |
| 43. The plaintiff asserts that the Defendant, Mitchell Tannis, continued to be the de facto business manager in the office where the Defendants (and sexual harassment complainants), Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee, and Laura Dato worked, until his departure on or about February 1997. The plaintiff asserts that the Defendant Mitchell Tannis did attend the premises of Tannis Printing Ltd. and later Aurora-M.T. Publishing and later Calvary Publishing Corp., on a daily basis until his departure (based primarily on the guilty verdict relating to cheque kiting). |
| 44. The plaintiff asserts that he wrote and provided each of the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, Joseph Dauo, Sarah Clemente, Angela Abbate, and Laura Dato with a formal Sexual Harassment Policy for the Tannis Group of Companies which set out guidelines and provisions of conduct with regards to sexual harassment complaints in the workplace, which included, but was not limited to, the provision that any employee who believed they were being sexually harassed, was obliged to document their complaint in writing, and submit it to a manager or company owner within 1 week of the incident. The plaintiff further alleges that he was commissioned to create this Sexual Harassment policy by Mitchell and Nadine Tannis, his employers at the time, on or about March of 1996, as a consequence of a sexual harassment claim that had been filed by a Tannis Printing Ltd. employee against Jacob Jones, which claim was later dropped, after a number of communications between lawyers representing the two parties. The plaintiff Glen P. Robbins further asserts that he had been directed by his employers, the Defendants Mitchell and Nadine Tannis, to deal with the sexual harassment complaint in order to limit the liability of the Tannis Group of Companies in such matters. The plaintiff further asserts that although the sexual harassment complaint was not followed through by the complainant, that the plaintiff ultimately asked Mr. Jones to swear an affidavit to support Mr. Jones contention that no sexual harassment occurred. The plaintiff further asserts that Mr. Jones declined to swear such an affidavit and subsequently resigned from Tannis Printing Ltd. |
| 45. The plaintiff asserts that, had he received any notification, either via procedures outline in the Tannis Group of Companies Sexual Harassment Policy, or via the owners Mitchell and Nadine Tannis, or via any other means, that one or more employees of the Tannis Group of Companies felt that the plaintiff had subjected them to any form of harassment, sexual or otherwise, during the approximately 11 months that the plaintiff worked for the Tannis Group of Companies, then the plaintiff asserts, that he would have immediately and willingly tendered his resignation and abandoned any involvement with said Tannis Group of Companies, as there were, in fact, no substantive reasons for the plaintiff to have remained associated with said companies. The plaintiff further asserts that at no time, did the Defendants Mitchell or Nadine Tannis speak to, or write to the plaintiff concerning any alleged complaint or concerns of harassment, sexual or otherwise, by the plaintiff of any employee or person working for, or outside of the Tannis Group of Companies. The plaintiff further asserts that the reason that he received no notification of any kin concerning any incident of harassment, sexual or otherwise, from his employers the Defendants Mitchell and Nadine Tannis, was because, the plaintiff asserts, no harassment occurred, or in the alternative, the Defendants Mitchell and Nadine Tannis chose not to take any action to notify the plaintiff for reasons unknown to the plaintiff. |
| 46. The plaintiff alleges that the Defendants, Mitchell Tannis, Nadine Tannis, Jennifer Tannis, and Joseph Dauo, unbeknownst to the plaintiff, expected to use their 'friendship' and business relationship with the plaintiff in order to establish a 'front', behind which they could continue to fraudulently operate in order to continue to draw large amounts of cash from the Tannis Group of Companies during and following the Petition of Bankruptcy proceedings against the Defendants, Mitchell Tannis, Nadine Tannis and Joseph Dauo, who were subsequently petitioned into bankruptcy by the Supreme Court of British Columbia on or about October 16, 1996. To that end, the plaintiff alleges that the Defendant Mitchell Tannis insisted on managing the daily business affairs of the Tannis Group of Companies, and later, Aurora-M.T. Publishing, until his departure on or about February of 1997. The plaintiff further alleges that the aforementioned Defendants became angry when the plaintiff refused to cooperate with their various schemes to evade the Order of Bankruptcy. The plaintiff alleges that the aforementioned Defendants felt that the plaintiff owed them a debt of obligation, which they believed, the plaintiff alleges, he was not repaying. The plaintiff further contends that the aforementioned Defendants conspired with the Complainants and others in an attempt to ruin his reputation, to ruin his business and to extort money from the plaintiff, when they determined that he was of no further use to them. |
| 47. The plaintiff asserts that the Defendant, Joseph Dauo, and his wife, the Defendant Rose Dauo, were angry and blamed the plaintiff when they lost their family home in Coquitlam, B.C., as a consequence of the bankruptcy of the Defendants, Mitchell and Nadine Tannis, effective on or about October 16, 1996 pursuant to the order of Madame Justice Loo. The plaintiff asserts that the Defendant Joseph Dauo file for bankruptcy on or about the Spring of 1997. The plaintiff alleges that the Defendants Joseph and Rose Dauo, blamed the Plaintiff for their financial hardships and undertook to seek revenge by engaging in a number of actions designed to defraud or extort money from the plaintiff, and to ruin the plaintiff's reputation in the business community, and at large, including but not limited to, filing a false claim for lost wages with the Employment Standards Branch of the B.C. Ministry of Labour, and by attempting to persuade, or in the alternative persuading, various female members of the Calvary Publishing Corp., staff to lie, and to file false accusations of sexual harassment with the Defendant, the B.C. Human Rights Commission. |
| 48. The plaintiff alleges that the Defendants Mitchell Tannis and Joseph Daou, objected to the Plaintiff's 'Fairness Policy' of deducting the costs of cancelled advertisement sales, from their commissions. The plaintiff asserts that the Fairness Policy had been introduced by the plaintiff on or about November of 1996, and that the aforementioned Defendants had been given six months notice of the plaintiff's intention to implement said Fairness Policy. The plaintiff asserts that the policy was developed as a result of the high cancellation rate of approximately 60-70%, for the sales of advertising which the Defendants, Mitchell Tannis and Joseph Daou wrote up, for which they expected to be paid full sales commissions. The plaintiff asserts that most of the administrative work of the Defendants, Angela Abbate, Glenda Lee, Laura Dato and Sarah Clemente was directly related to the processing, invoicing, cancelling and seeking client approval for, the sales of the Defendants, Mitchell Tannis and Joseph Dauo. The plaintiff alleges that each of the aforementioned Defendants refused to abide by the fairness sales policy when it was implemented by the plaintiff Glen P. Robbins on or about May 1997, and the aforementioned Defendants were angered when their net sales commissions dropped substantially when their 'bad' sales were deducted from their sales commission cheques. (The B.C. Employment Standards decision was to pay Joseph Daou sales commissions on advertising that he wrote up as sold--but was never paid for--that's correct---believe it or not). |
| 49. The plaintiff asserts that following the resignation of the Defendants Mitchell Tannis and Joseph Daou on or about May of 1997, the daily advertising sales volume for Calvary Publishing Corp. was reduced from approximately $11,000 per day to approximately $6,000 per day, resulting directly in a correspondingly large reduction in the administrative man hours required to process the related paperwork. The plaintiff asserts that this reduction in administrative man-hours lead to overstaffing in the administration area in the summer of 1997. |
| 50. The plaintiff alleges that the Defendants, Mitchell Tannis and Nadine Tannis, know, and have social and other influential relationships with, the friends and families of the Defendants, Sarah Clemente, Angela Abbate, Glenda Lee, Laura Dato, through their social and religious affiliations with Holy Cross Roman Catholic Church and other affiliated organizations. The plaintiff further alleges that the Defendants, Mitchell and Nadine Tannis had known the Defendants, Sarah Clemente, Angela Abbate, Laura Dato for most, if not all of their lives, as friends of the Tannis family. The plaintiff further asserts that these same Defendants were deeply indebted to the Tannis family, for providing employment opportunities to them. The plaintiff further asserts that the Defendant, Laura Dato had been employed by the Defendants, Mitchell and Nadine Tannis on a part time basis from the approximate age of 13 years old (are adults now). |
| 51. The plaintiff alleges that the Defendants Mitchell Tannis, Nadine Tannis, Joseph Dauo, and Jennifer Tannis had motive and opportunity to exert a strong influence over the Defendants Sarah Clemente, Angela Abbate, Glenda Lee, and Laura Dato, when the decision was made to accuse the plaintiff of sexual harassment. The plaintiff further asserts that the Defendant Jennifer Tannis had been a longtime friend and classmate at school with each of the Defendants Sarah Clemente, Angela Abbate, and Glenda Lee. The plaintiff further asserts that the mothers of the Defendants Angela Abbate and Laura Dato are biological sisters and longtime friends of the Defendants Mitchell and Nadine Tannis. The plaintiff further asserts that the Defendant Sarah Clemente lived with the Defendants Mitchell, Nadine and Jennifer Tannis for extended periods of time when she was not welcome in her own family home. |
| 52. The plaintiff alleges that the Defendants, Mitchell and Nadine Tannis have had, and continue to have, a strong influence over their children and their children's friends, through their dominant role in the church and affiliated organizations and through the man social and quasi-religious functions which were regularly held in their home. The Plaintiff Glen P. Robbins further alleges that these regular social and quasi-religious gatherings gave the Tannis family ample opportunity to influence each of the complainants, Defendants Sarah Clemente, Angela Abbate, Glenda Lee, Laura Dato and their own daughter Jennifer Tannis, with regars to their decision to file their various sexual harassment complaints against the plaintiff with the B.C. Human Rights Commission. The plaintiff further alleges that the close relationship between the complainants and the Tannis family afforded the complainants ample opportunity to plan, discuss, prepare and rehearse their various sexual harassment claims, so as to be able to corroborate each other's testimony during the proceedings. |
| 53. The plaintiff asserts that the office where the Defendant, Mitchell Tannis and the Complainants, Defendants Angela Abbate, Sarah Clemente, Glenda Lee, Laura Dato and Jennifer Tannis worked, was divided into two sections with a total area of approximately 800 square feet. The Defendant, Jennifer Tannis, worked in the front or customer service section, while the other Complainants worked in the rear administration section. The plaintiff Glen P. Robbins asserts that the Defendant Mitchell Tannis (58 years old at the time), occupied a desk in the administration section of the office in a central position which afforded him a view of the entire adminstration office, plus a view of the front section. The plaintiff further asserts that the Defendant, Mitchell Tannis, was at his desk from approximately 8:30 in the morning, until the close of business at approximately 5:30 to 6:00 in the evening, on a daily basis, every week, and that the Defendant Mitchell Tannis, did not as a rule, go out for lunch. The plaintiff asserts that he witnessed the Defendant Mitchell Tannis's daily routine, which did not vary from approximately February of 1996, until the Defendant, Mitchell Tannis, began working from home, on or about February of 1997. The plaintiff further asserts that the Defendant, Mitchell Tannis, worked at a desk, within approximately 15 feet and within sight and within earshot of every one of the Complainants, for the entire period of time from approximately February of 1996 to approximately February of 1997 while the alleged sexual harassment occurred. The plaintiff further asserts that the Defendant, Mitchell Tannis, swore an affidavit in which he stated that he was not aware of any sexual harassment taking place within the aforementioned office (a legal affidavit), in which affidavit the Defendant Mitchell Tannis lied, or in the alternative, the Defendant Mitchell Tannis--father of the Defendant and sexual harassment ringleader Jennifer Tannis---spoke the truth BECAUSE AS HE SAYS IN THE AFFIDAVIT--NO SEXUAL HARASSMENT OCCURRED. The plaintiff Glen P. Robbins alleges that, had sexual harassment occurred, it would have been virtually impossible for the Defendant Mitchell Tannis to be unaware of it. The plaintiff further alleges that, if sexual harassment had taken place, then the Defendant, Mitchell Tannis knew, or ought to have known, that it was taking place, and knew or ought to have known, that it was his responsibility as owner and employer, to deal with it in order to mitigate the damages to himself, to his company and to the complainants. |
| 54. The plaintiff asserts that he did not regularly work in either of the two sections of the office where the Complainants and the Defendant Mitchell Tannis worked, except for a period of approximately two weeks in February of 1996. The plaintiff asserts that his office was in another building altogether, on the second floor, next to the sales office in an office that was previously used by Mitchell Tannis's 'adopted' son Defendant Josepeh Dauo. The plaintiff further asserts that he spent an average of less than one hour at any time, on an infrequent basis, in the administrative and front areas of the office occupied by the Complainants and the Defendant Mitchell Tannis. The plaintiff Glen P. Robbins further asserts that the Defendant Mitchell Tannis, would approach the plaintiff whenever he entered this office and monopolize his time by talking to the plaintiff to the extent that the plaintiff tended more often then not to avoid this office for days and even weeks at a time. |
| 55. The plaintiff asserts that the defendant Jennifer Tannis, stated in her original complaint filed with the Defendant, the B.C. Human Rights Commission, which was written in her own hand, signed by her and dated June 13, 1997, under the heading of the government legal document "Witnesses", that the plaintiff's sexual harassment was witnessed by "Every worker at Calvary Publishing Corp." and "I found w/{sic} Glen's abuse is beyond words especially when it was done in front of the whole staff." The plaintiff further asserts that the Defendant, Jennifer Tannis, stated in her original complaint filed with the B.C. Human Rights commission, that "When 2 MALE workers told me to report to Glen, all I could do was cry." However, the plaintiff further asserts that the Complainants produced only one witness at the Defendant, the B.C. Human Rights Tribunal hearing of the Complainants in June of 2000, who was the swarthy Arab--Defendant Joseph Daou, whose testimony was given "no weight" by the presiding Tribunal Member/BC Judge, Defendant Tom Patch, due to the Defendant, Joseph Daou's evident "animosity" toward Glen P. Robbins. The Defendant further alleges that the Defendant Jennifer Tannis could not secure her own father, Mitchell Tannis' witness testimony--despite working within three feet of her father during the period of the alleged harassment--for over one year because Glen P. Robbins alleges Arab-Catholic Defendant Mitchell Tannis failed to witness (as evidence by his own sworn affidavit), or in the alternative ignored, any and all of the alleged sexual harassment of the Complainants, including his own daughter Jennifer Tannis, which the plaintiff alleges is because none of the alleged sexual harassment occurred. |
| 56. The plaintiff further asserts that the Defendant, Jennifer Tannis, in her original complaint filed with the Defendant, the B.C. Human Rights Commission, alleged that "Sexual Harrassement {sic} occured {sic} whenever Glen Robbins was present (Daily & hourly basis.)", (sic} beginning in "Feb/96: The 1st week Glen was working at Tannis (now Calvary)...". The plaintiff asserts that in so saying, the Defendant Jennifer Tannis, alleges that she was subjected to hundreds of incidents of sexual harassment by the plaintiff in the presence of her father, the Defendant Mitchell Tannis. The plaintiff further asserts that the Defendant Jennifer Tannis, stated that "I terminated myself from Calvary two weeks ago {allegedly, the end of May 1997} & told my parents the whole story." The plaintiff alleges that it would have been virtually impossible for the Defendants Mitchell and Nadine Tannis to not know about the alleged sexual harassment of the Defendant Jennifer Tannis, if it had occurred as was alleged, in their presence over an 11 month period--"every day and hour" as Jennifer Tannis asserts in her original hand written letter. The plaintiff further alleges that none of the alleged sexual harassment occurred and that the Defendant Jennifer Tannis lied, or in the alternative, the plaintiff alleges that the alleged sexual harassment was done with the full knowledge and therefore consent of the Defendant Jennifer Tannis's employers, her father and mother, the Defendants Mitchell and Nadine Tannis. |
| 57. The plaintiff asserts that the Defendant Jennifer Tannis, in her original complaint filed with the BC Human Rights Commission, alleged that "I would confront Glen whenever he harassed, but 1/2 of the time I was so used to it that I tried to ignore his insults. When I did confront him I'd say I'm going {sic} complain/sue you sex Harass'''(sic}. The plaintiff therefore alleges, that the Defendant Jennifer Tannis claims that she explicitly told the plaintiff that she was considering suing or filing a complaint of sexual harassment against the plaintiff virtually on a daily basis---harassment that allegedly occurred for an entire calendar year. The plaintiff further asserts that the Defendant Jennifer Tannis never spoke to the plaintiff about any of the sexual harassment that the plaintiff is alleged to have perpetrated against her or any of the other Complainants. |
| 58. The plaintiff asserts that the Defendant, Jennifer Tannis acted on behalf of Calvary Publishing (a proprietorship at the time) in conjunction with the plaintiff on or about the spring of 1996, agreeing to purchase the assets of the Tannis Group of Companies in return for assuming some of the liabilities of the companies, which agreement was later ratified by the incorporation of the company, Calvary Publishing Corp. on or about September 1996. The plaintiff asserts that the Defendant Jennifer Tannis became an officer, director, and 50% shareholder of Calvary Publishing Corp. The plaintiff further asserts that the Defendant Jennifer Tannis, sold her interest in Calvary Publishing Corp. to the plaintiff for $30,000 on or about February 1997. The plaintiff therefore asserts that if Calvary Publishing Corp is found to be a legal entity which employed the complainants during the period beginning on or about September of 1996, and ending on or about February of 1997, then the Defendant Jennifer Tannis, should also have been named a Respondent to the sexual harassment complaints, or in the alternative, the Defendant, the BC Human Rights Commission, should have refused to hear the Defendant Jennifer Tannis's complaint on the basis that she was an employer during some or all of the time that the alleged sexual harassment occurred. |
| 59. The plaintiff, Glen P. Robbins alleges that the Defendant, Jennifer Tannis--currently a Las Vegas 'Dancer', acted as a de facto director and manager of Tannis Group of Companies and as a bona fide director and de facto manager of Calvary Publishing Corp. during the period from February of 1996, until she quit on or about March of 1997. The plaintiff further asserts that the Defendant Jennifer Tannis, in her original complaint filed with the Defendant, the B.C. Human Rights Commission, stated that "I was working to be a manager or boss...". The plaintiff further alleges, that the Defendant Jennifer Tannis, acted as a manager or boss when she hired the Defendant Glenda Lee (her school friend) as a part-time employee on or about October of 1996 and then promoted the Defendant Glenda Lee to full-time in January 1997. The plaintiff further alleges, that the Defendant Jennifer Tannis, acted as a manager or boss when she provided a comprehensive list of names and details about other "Victims" of sexual harassment in her complaint which was filed with the B.C. Human Rights Commission. The plaintiff further alleges that the Defendant Jennifer Tannis, became a director and owner of the new Tannis company T.E.G. Generation II Ltd. shortly after quitting Calvary Publishing Corp in March of 1997. The plaintiff further alleges that the Defendants the BC Human Right Commission, and the Defendant Christopher Finding failed to act on the plaintiff's missives and other communications regarding the conflict of interest and failed to find the Defendant Jennifer Tannis, to be an employer during all, or part of the time in which sexual harassment was alleged by the complainants. |
| 60. The plaintiff asserts that the Defendant Jennifer Tannis, in her testimony to Defendant-the B.C. Human Rights Tribunal, as paraphrased by the Defendant Tom Patch in his Reasons for Decision indexed as: Tannis et al v. Calvary Publishing Corp. and Robbins, 2000 BCHRT 47, testified that "In March, she told her manager that she wanted to work at home. She was allowed to do telephone sales from home, working with her brother and uncle." The plaintiff asserts that no such arrangement was ever made or authorized by the plaintiff. The plaintiff further asserts that the Defendant Jennifer Tannis in fact, quit her employment at Calvary Publishing Corp on or about March of 1997. The plaintiff alleges that, while it is possible that the Defendant Jennifer Tannis may have assisted the Defendants Mitchell Tannis, Joseph Dauo, their 'Uncle Pat' and Christian Tannis in doing telephone sales from their home, that in fact the Defendant Christian Tannis was the only authorized commission sales contractor doing sales for Calvary Publishing Corp. in the name of the Defendant Christian Tannis only. The plaintiff further alleges that the aforementioned Defendants were in fact already engaged in planning to start their new company on or about March of 1997, and were engaged in 'stealing' the business of the plaintiff by slandering the reputation of the plaintiff, while continuing to bill the plaintiff for sales commissions via their nominees the Defendant Christain Tannis. |
| 61. The plaintiff asserts that there are numerous, substantive inconsistencies between the original complaint that the Defendant, Jennifer Tannis, filed with the Defendant the B.C. Human Rights Commission on June 13, 1997, the Witness Statement provided by the Defendant Heenan Blaikie on or about April 1999 by the Defendant, Tonie Beharell, and the sworn testimony which the Defendant Jennifer Tannis gave before the B.C. Human Rights Tribunal in June of 2000, including but not limited to, conflicting testimony as to when the Defendants Nadine Tannis and Mitchell Tannis left Calvary Publishing Corp. ("...parents left Calvary Publishing in the Fall of 1996"; He {Mitchell Tannis} left in late fall of 1996"; "After Mitchell Tannis left the office in 1997..." and contradictory statements, as to when the Defendant Jennifer Tannis first told her parents about the alleged abuse; "events which occurred on her parent's anniversary boat cruise in April 1996...Robbins' reaction towards her, "after she had discussed his behaviour with her mother", who spoke to Robbins"; "Ms. Tannis subsequently spoke to her mother and told her that Robbins was staring." "She did not talk to her parents about what was happening because they were going through a very hard time"; "I terminated myself two weeks ago {dated on or about June 13, 1997} and told my parents the whole story." The plaintiff Glen P. Robbins alleges the differences in the Defendant Jennifer Tannis's respective statements result from her ongoing attempts at fabrication and manipulation of elements of her story in order to support the sexual harassment complaints against the plaintiff. |
| 62. The plaintiff asserts that he has in his possession dated documentary evidence, in the form of a poster-sized Christmas card which was hand-made by the Defendant Jennifer Tannis, which is dedicated "To Glen" and which contains personal greetings such as "With Love" and is signed by each of the Defendants Jennifer Tannis, Sarah Clemente, Angela Abbate, Christian Tannis, Laura Dato, Mitchell Tannis, Nadine Tannis and Joseph Daou (all of the complainants except Glenda Lee who had not been hired yet--and another complainant--a prostitute named Kimberly Corbett-whose complaint was dropped when they found out she was a prostitute), among others, which appears to demonstrate a warm and friendly relationship between each of these Defendants and the plaintiff on or about December of 1996. The plaintiff alleges that this documentary evidence suggests that no sexual harassment had occuured in the 11 months prior to Christmas of 1996 (the date of the glowing Christmas card)-because there is no evidence of any ill will borne by the Complainants against the plaintiff at the time that this card was made and signed. |
| 63. The plaintiff asserts that in November of 1996 the Defendant Jennifer Tannis organized a birthday party for the plaintiff, which was an event that was completely beyond the scope of her duties within the context of the business relationship that the Defendant, Jennifer Tannis, had with the plaintiff Glen P. Robbins, in which the plaintiff asserts, he had no knowledge, or role in initiating or organizing, and which the plaintiff contends, would have been completely inappropriate given the Defendant Jennifer Tannis has alleged that she had been sexually harassed by the plaintiff for a period of more than 10 months prior to the party. The plaintiff further asserts that the Defendant Jennifer Tannis, organized a Christmas party in December of 1996, in honour of the plaintiff, at which time the aforementioned poster-sized Christmas card was presented to the plaintiff. |
| 64. The plaintiff asserts that the Complainant and Defendant, Jennifer Tannis, was a partner, shareholder, officer, and working Director of Calvary Publishing Corp., and further that Jennifer Tannis worked within a few feet of her father the Defendant Mitchell Tannis, and within a few feet of each of her fellow Complainants, all of whom are Defendants referred to in this claim. The plaintiff further asserts that as a consequence of the Defendant Jennifer Tannis's role as 50% owner of Calvary Publishing Corp., and the proximity to her father Mitchell Tannis, and her long time relationship and proximity to the other complainants, that she should have been expected, on a balance of reasonable probabilities, to have been provided with sufficient opportunities to have taken appropriate steps to halt the sexual harassment against herself and others, and that she did not do so the plaintiff alleges, is strong evidence to suggest that there never was any sexual harassment. Further, the plaintiff alleges that if there was any sexual harassment against the Complainants, then the plaintiff alleges that the Defendant, Jennifer Tannis, is equally as liable as the plaintiff, to the other Defendants who filed sexual harassment complaints. |
| 65. The plaintiff asserts that the Defendant Jennifer Tannis asked to speak with him on two separate occasions on or about the Fall of 1996, supposedly about business, but in fact, the plaintiff alleges that the Defendant, Jennifer Tannis was actually desirous of talking about her father, the Defendant Mitchell Tannis's emotional and sexual abuse of her brothers and sisters. During both discussions with the Defendant Jennifer Tannis the plaintiff asserts that she alleged details about abhorrent sexual activity and cried openly...about said abuse, and told the plaintiff about the effects that this had had on the Defendant's family. The plaintiff asserts that he found the personal and sexual nature of these conversations to be unwelcome and upsetting. The plaintiff further asserts that he doubted that these events had actually occurred, and the plaintiff further asserts that he believed these conversation with the Defendant Jennifer Tannis to be symptomatic of the dysfunctional family environment in which the Defendant Jennifer Tannis, had apparently been raised. |
| 66. The plaintiff alleges that the Defendant Jennifer Tannis, became angry with the plaintiff, when he began to take control of the daily operations of Calvary Publishing Corp. after her father left on or about February of 1997. The plaintiff further alleges that the Defendant Jennifer Tannis did not like the plaintiff's new methods of running the company and frequently made references as to how her father, the Defendant Mitchell Tannis wanted to have, or would have run the company. The plaintiff further alleges that his dismissal of her complaints about how the plaintiff operated Calvary Publishing Corp angered the Defendant Jennifer Tannis. The plaintiff further alleges that the Defendant Jennifer Tannis's job performance declined rapidly following her father's departure and that the plaintiff did not conceal his dissatisfaction with the Defendant Jennifer Tannis's quality of work. |
| 67. The plaintiff alleges that the Defendant Jennifer Tannis was upset when she realized that the plaintiff intended to lay some of the complainants off due to lack of work in the spring or early summer of 1997. The plaintiff asserts that the complainants and each of them were all friends of the Defendant Jennifer Tannis, and that they were all upset when it became evident that the plaintiff was attempting to decide which employees he would keep, and which would have to be laid off due to lack of work. The plaintiff alleges that the Defendant Jennifer Tannis continued to be in touch with the other complainants after she left Calvary Publishing Corp. and acted to organize their allegations of sexual harassment against the plaintiff. In her hand written statement to the the BC Human Rights Commission date June 13, 1997 and signed by Jennifer Tannis, she stated; "My co-worker phoned a lawyer 2 months ago to ask if there's anything we could to (sic) against Glen but the lawyer told us there's no chance unless Glen touched us." and "..I am willing to help his victims and bring as much justice to light as possible." Glen P. Robbins alleges that Jennifer Tannis conspired with the other complainants, and with other members of the Tannis family to seek revenge against the Plaintiff by organizing and filing false accusations of sexual harassment with the Defendant the BC Human Rights Commission. |
| 68. The plaintiff asserts that after the Defendant Jennifer Tannis approached the plaintiff on or about April 1997 and asked him to falsify a Record of Employment so that the Defendant Jennifer Tannis could collect Unemployment Insurance benefits (now Employment Insurance benefits). The plaintiff asserts that he informed the Defendant Jennifer Tannis, that she was not eligible to include the period of time in which she was an owner of Calvary Publishing Corp., and that to do so would require an act of fraud. The plaintiff alleges that his angered Jennifer Tannis. |
| 69. The plaintiff asserts that he denies the validity and substance of all of the Defendant Jennifer Tannis's claims of sexual harassment, and in particular, but not limited to, the Defendant Jennifer Tannis's sworn testimony that he is "sick" and a "pedophile", and sworn testimony and written complaint that he sexually molested, or that he spoke about sexually molesting, a nine, or in the alternative, a ten year old girl in a Catholic school where the plaintiff taught. The plaintiff asserts that these statements, made and accepted as part of the Defendant Jennifer Tannis's testimony to the Defendant the B.C. Human Rights Tribunal in June of 2000 by the Defendant Tom Patch, are completely false, and that these statements were uttered by the Defendant Jennifer Tannis, for the sole purpose of defaming, slandering and ultimately libeling the plaintiff. The plaintiff further alleges that the aforementioned statements were and are irrelevant to the Defendant Jennifer Tannis's contention that the plaintiff discriminated in employment against the Defendant Jennifer Tannis on the basis of her sex through sexual harassment. |
| 70. The plaintiff asserts that the Defendant (and sexual harassment complainant) Sarah Clemente, stated in her original complaint filed with the Defendant, the BC Human Rights Commission, which was signed by her and dated on or about June 18, 1997, that "My complaint first started in March of 1996 when I was working for Mitchell Tannis of Tannis Printing Ltd." The plaintiff further asserts that the Defendant wrote in her complaint that "...he (the plaintiff) would tell me everyday (that I was really pretty and had a nice body} or every other day and I was feeling disgusted." The plaintiff alleges that the Defendant Sarah Clemente's complaints corroborate the Defendant Jennifer Tannis's complaints, that the alleged sexual abuse began immediately upon meeting the plaintiff and occurred daily, in the presence of the complainant's employer, the Defendant Mitchell Tannis at Tannis Printing Ltd. The plaintiff further alleges that the Defendant the BC Human Rights Commission, and the Defendant Christopher Finding erred when they did not include the Defendant Mitchell Tannis as a respondent to the sexual harassment complaints filed by the complainants. The plaintiff further alleges that the Defendant Mitchell Tannis, knew or ought to have known about the alleged sexual harassment, or in the alternative, no sexual harassment occurred and the Defendant Sarah Clemente is lying. |
| 71. The plaintiff asserts that the Defendant Sarah Clemente, provides considerable detail in her written complaint to the Defendant the BC Human Rights Commission, about the alleged sexual harassment which took place during the anniversary party for the Defendants Nadine and Mitchell Tannis, on or about April of 1996, which includes, but is not limited to the statement "Mrs. Tannis had also talked to me that she had talked to him (the plaintiff Glen P. Robbins), and so for a while he (the plaintiff) did stop telling me that I was pretty..." The plaintiff asserts that the Defendant Sarah Clemente also stated that, "...Rosie Daou (the Defendant Rosie Daou, wife of the Defendant Joseph Daou) had jokingly said that I, (Sarah Clemente) is (sic) going to file a Human Rights Complaint against him." The plaintiff alleges that these and other statements in the complaint written by the Defendant, Sarah Clemente, corroborate other evidence, that the Defendant Nadine Tannis was allegedly made aware of the alleged sexual harassment allegedly perpetrated by the plaintiff as early as April of 1996, but allegedly failed to act on these complaints in her role as an owner of Tannis Printing Ltd., or in the alternative , that no sexual harassment occurred because the complainants have evident difficulty in managing their respective stories. The plaintiff further alleges that the Defendant, the BC Human Rights Commission, and the Defendant, Christopher Finding erred when they did not include the Defendant Nadine Tannis as a respondent to the sexual harassment complaints filed by the complainants. The plaintiff further alleges that these same statements in the complaint written by Sarah Clemente, refute the sworn testimony of the Defendant Jennifer Tannis, that she allegedly did not tell her parents about the alleged sexual harassment by the plaintiff, or in the alternative, her parents, the Defendants Nadine and Mitchell Tannis, had no knowledge of the alleged sexual harassment of their employees the complainants, by their employee, the plaintiff. The plaintiff alleges that this is proof that no sexual harassment had occurred, or in the alternative, that the Defendants Mitchell and Nadine Tannis, owners of Tannis Printing Ltd. were fully aware of the alleged sexual harassment, more than one year before the complaints were filed, and subsequently did little or nothing about it. |
| 72. The plaintiff asserts that two employees of Calvary Publishing Corp., swore affidavits that the Defendants Sarah Clemente and Angela Abbate frequently and consistently wore inappropriate and revealing clothing in the work place. The plaintiff alleges that on at least one occasion, the Defendant Sarah Clemente appeared to be intentionally exposing her genitals to the plaintiff, or in the alternative, was dressed so provocatively that she was unaware that she was exposing her genitals to the plaintiff, which actions, the plaintiff asserts, were not welcomed by the plaintiff and of a sexually harassing and disturbing nature. As a result of their consistently provocative and unprofessional style of dressing, the plaintiff asserts that he made the decision to take the Defendants Sarah Clemente and Angela Abbate shopping so that they could purchase appropriate business attire for their new positions as co-managers, on or about the summer of 1997. |
| 73. The plaintiff alleges that during the period of time between approximately October of 1996 and approximately January of 1997, the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, Angela Abbate, and Laura Dato confronted him both individually and collectively on not less than 30 occasions to complain that the Defendant Sarah Clemente's genitals gave off an unpleasant odor. They insisted both jointly and severally that the odor from her genitals was making them nauseous and that they were in some cases suffering terrible headaches as a result. The plaintiff further alleges that each of the Defendants herein described the odor as "fishy" and "like rotten cheese". Each and every time the complaints were made, the Defendants Mitchell and Nadine Tannis would thereafter attempt to convince the plaintiff to speak to the Defendant Sarah Clemente about the problem. The plaintiff asserts that he did not work in the same building or office with the Defendants and that he told the Defendants Mitchell and Nadine Tannis that he (the plaintiff) was not comfortable, and did not find it appropriate that he should discuss matters of hygiene with female employees. The plaintiff asserts that as a result, he began to park his automobile great distances from the office, and would try to "sneak" into his own office via a back stairway in order to avoid that he came to view as an embarrassing and sexually harassing situation. The plaintiff alleges that this situation constitutes sexual harassment of the plaintiff by the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, Angela Abbate and Laura Dato. |
| 74. The plaintiff asserts that he gave raises and promotions to the Defendants Sarah Clemente and Angela Abbate in recognition of the fact that he was expecting them to take on additional responsibilities and to increase their productivity. The plaintiff asserts that the changing business situation required him to reduce staffing levels and require more diligence on the part of the remaining staff. The plaintiff alleges that the complainants resented being asked to do additional work, despite the fact that they were being paid considerably better than the average wage for their skill levels. The plaintiff asserts that the Defendant, Sarah Clemente, on being promoted to manager on May 6, 1997 'complained' in her written complaint to the Defendant the BC Human Rights Commission. "Although I already work hard enough for him, he wanted me to come to work earlier than usual, I start at 8:30 AM and leave later than usual, I finish at 5:30 PM." and also Clemente writes "During this week {week of July 7, 1997}, I had so much pressure on me because Angela {Abbate} wasn't there so I had twice as much to do." The plaintiff alleges, that the Complainants resented the fact that he broke up the 'after school social club' work environment that they had enjoyed and had been used to, while working for the Defendant Mitchell Tannis. The plaintiff alleges that this resentment became a motive for the Complainant's decision to seek revenge against the plaintiff by filing false sexual harassment complaints. |
| 75. The plaintiff asserts that the primary function of the Defendants Angela Abbate, Laura Dato, Glenda Lee and Sarah Clemente was to process adminstrative paperwork which directly resulted from the sales of advertising in the various publications distributed by Tannis Printing Ltd., and later, Aurora-M.T. Publications and later, Calvary Publishing Corp. The plaintiff asserts that when the Tannis family, including the Defendant Mitchell Tannis, ceased doing sales for the plaintiff on or about May of 1997, the workload of the adminstration department was reduced by approximately one half, corresponding directly to the reduction in daily sales volume from approximately $11,000 to $6,000 per day, and the corresponding reduction in cancelled sales, which had been approximately 60-70% of total sales. The plaintiff asserts that it was this reduction in sales volume and the corresponding reduction in sales cancellations, and not the threat of sexual harassment complaints, that lead to the eventual layoff of Angela Abbate and Laura Dato. |
| 76. The plaintiff asserts that he encouraged the Defendant Sarah Clemente to attend to two business related courses in order to improve her skill set for the management role that he planned for her. The plaintiff further asserts that Calvary Publishing Corp. paid for both courses, but to the best of the plaintiff's knowledge, the Defendant Sarah Clemente never completed either course. The plaintiff asserts that he did everything possible to encourage the Defendant Sarah Clemente to develop a professional attitude and to improve her skills while she was employed with the plaintiff. |
| 77. The plaintiff, Glen P. Robbins alleges that the Defendant Sarah Clemente, had two garnishments placed against her wages in 1997. The plaintiff alleges that the Defendant Sarah Clemente, appeared to be suffering from substance abuse problems, which seemd to diminish her ability to manage her life, her finances, and her ability to concentrate and to do her job. The plaintiff asserts that the Defendant Sarah Clemente occasionally missed work, and occasionally under-performed at work, because she appeared, on occasion, to be suffering from the after-effects of excessive alcohol consumption. |
| 78. The plaintiff asserts that the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, and Joseph Daou sought to exploit the Defendant Sarah Clemente's personal and financial vulnerabilities in spring or summer of 1997 by convincing her to quit work at Calvary Publishing Corp. to collect Unemployment Insurance benefits (now Employment Insurance benefits), which would provide the Defendant Sarah Clemente with a net pay equal to what she could otherwise anticipate receiving, net of deductions and garnishment, and so that she could take the rest of the Summer of 1997 off from work, and to join the conspiracy to accuse the plaintiff of sexual harassment in order to receive additional compensation. The plaintiff alleges that the Defendant Sarah Clemente, did in fact quit her job without notice or just cause, on or about July of 1997. |
| 79. The plaintiff asserts that he witnessed the Defendants Sarah Clemente and Joseph Daou kissing in a parked car on or about July of 1997, which demonstrates that these two Defendants had some kind of intimate relationship about the time her sexual harassment complaints were being filed with the Defendant the BC Human Rights Commission. |
| 80. The plaintiff alleges that the Defendant Sarah Clemente, took premeditated actions prior to her un-announced departure from Calvary Publishing Corp. on or about July of 1997 which caused serious damage to the administration of the plaintiff's company. The plaintiff alleges that these actions were wilful and vexatious. The plaintiff further alleges that when the Defendant Sarah Clemente, quit her employment at Calvary Publishing Corp., dozens of cheques written to creditors and others, which were duly endorsed by the plaintiff for immediate payment, were deliberately withheld, and were in fact intentionally hidden, by the Defendant Sarah Clemente, who was responsible for their safe handling, and those payments to creditors and others were later found in various places throughout the administration office; in the bottom of desk drawers and in unrelated files. The plaintiff further asserts that following the time that the Defendant Sarah Clemente failed to return to work, dozens of corporate files and employment files were eventually found to be missing. The plaintiff asserts that the contention of missing Calvary Publishing Corp. documents has been well documented by independent legal counsel at Cobbett and Cotton law offices in the Summer of 1997. |
| 81. The plaintiff asserts that the Defendant Sarah Clemente, approached the plaintiff following her departure from Calvary Publishing Corp., and requested that the plaintiff lie and endorse her Record of Employment as "laid-off". The plaintiff alleges that when the plaintiff refused to lie, and instead endorsed her Record of Employment status with the designation "quit", then Sarah Clemente became angry with the plaintiff because it impaired her ability to collect U.I (now E.I.) benefits. The plaintiff further alleges that he was told by an agent for Employment Insurance at a later date, that she had told Sarah Clemente that the only way that she could qualify for Employment Insurance benefits immediately, was if she had been laid off, or in the alternative, if she had been sexually harassed on the job, which would require her to file a complaint with the Defendant, the BC Human Rights Commission. |
| 82. The plaintiff alleges that following the filing of a claim of sexual harassment with the BC Human Rights Commission in July of 1997 against the plaintiff, the Defendant Sarah Clemente was 'paraded' by the Defendant, Nadine Tannis up Hastings Street in full view of the remaining staff of Calvary Publishing Corp., to the law offices of O'Neill Rosenberg, located directly across the street from the offices of Calvary Publishing Corp., and thereafter the Defendant Nadine Tannis began to maliciously spread rumours of the impending sexual harassment claim against the plaintiff in the community, and to confirm the Defendant Sarah Clemente's part in it. |
| 83. The plaintiff further alleges that the Defendant Nadine Tannis, at or about the time that the Defendant Sarah Clemente's sexual harassment claims was filed, drove up and down the back alley behind the offices of Calvary Publishing Corp., in full view of Calvary salespeople, laughing and honking her car horn in order to disrupt regular business and to call attention the sexual harassment claims made against the plaintiff, with the clear intention of ruining the reputation of the plaintiff, as well as to damage the business prospects of the plaintiff within the community. |
| 84. The plaintiff asserts that he denies the validity and substance of all of the Defendant Sarah Clemente's claims of sexual harassment against him. |
| 85. The plaintiff asserts that the Defendant (and sexual harassment complainant), Angela Abbate alleges that sexual harassment by the plaintiff began immediately, when she was hired by Mitchell Tannis to work for Tannis Printing on or about May of 1996. The plaintiff further asserts that, in her sworn testimony given before the Defendant, the BC Human Rights Tribunal, as paraphrased by the Defendant Tom Patch in his Reasons for Decision, the Defendant Angela Abbate alleged that sexual harassment happened on a "daily" basis during the time that Mitchell Tannis, owned and managed Tannis Printing. The plaintiff alleges that the Defendant the BC Human Rights Commission, and the Defendant Christopher Finding erred when they did not include the Defendant Mitchell Tannis as a respondent to the sexual harassment complaints--or in the alternative subpoena his as a witness. The plaintiff alleges that the Defendant Mitchell Tannis knew, or ought to have known that sexual harassment was occurring in his office, or in the alternative, no sexual harassment was occurring. |
| 86. The plaintiff asserts that there are numerous, substantive inconsistencies between the original complaint that the Defendant Angela Abbate, filed with the Defendant, the BC Human Rights Commission on or about September of 1997, the Witness Statement provided by the Defendant Heenan Blaikie on or about April of 1999 by the Defendant Tonie Beharell, and the sworn testimony as paraphrased by the Defendant Tom Patch in his Reasons for Decision, which the Defendant Angela Abbate gave to the BC Human Rights Tribunal in June of 2000, including but not limited to, conflicting testimony regarding whether or not the Defendant, Angela Abbate received a layoff letter from Calvary Publishing Corp., "In July, 1997, Abbate received a lay off notice in the mail, but Robbins phoned her and told her she was not laid off and that she should return to work;"; "She (the Defendant Sarah Clemente) told Ms. Abbate that Mr. Robbins had told Ms. clemente to let Ms. Abbate go and send her a letter to lay her off. Ms. Clemente never sent the letter. The plaintiff asserts that Ms. Abbate then called Mr. Robbins and told him she had received her lay off letter. Mr. Robbins said that is was Ms. Clemente who wanted to let her go." The plaintiff alleges that the differences in the statements can be atributed to the fact that the Defendants Sarah Clemente and Angela Abbate are having difficulty managing their facts and fabrications with respect to the details of their sexual harassment claims, and the plaintiff therefore alleges that this is further proof that the sexual harassment claims are fraudulent. |
| 87. The plaintiff asserts that the Defendant Angela Abbate, when she testified before the Defendant, the BC Human Rights Tribunal, stated "...that there was not a shortage of work: rather Calvary was understaffed," which statement was in fact wrong, and the plaintiff asserts that the Defendant Angela Abbate was in no position, nor sufficiently competent to be able to judge whether or not Calvary Publishing Corp was over or understaffed. The plaintiff further asserts that the Defendant Sarah Clemente had effectively replaced the Defendant Angela Abbate, while Angela Abbate was 'off work'. |
| 88. The plaintiff asserts that the Defendant Angela Abbate told the Defendant the BC Human Rights Tribunal that "She took about a week off", because "she was stressed out because of the conditions at work..". The plaintiff alleges that the Defendant Angela Abbate only took time off work because of a claimed personal injury alleged to have been suffered as a result of a motor vehicle accident, for which the plaintiff alleges, the Defendant Angela Abbate was actively seeking compensation form the Insurance Corporation of British Columbia (I.C.B.C.) |
| 89. The plaintiff alleges that the Defendant Angela Abbate, confided to the plaintiff that her pending I.C.B.C. personal injury (File No. D965396) that was filed in the Supreme Court of B.C., on or about October of 1996, "wasn't a real injury". The plaintiff further alleges that the Defendant Angela Abbate, approached the plaintiff and asked if the plaintiff would "pay her under the table" for her services at Calvary Publishing Corp., while she was attempting to realize a financial settlement from her personal injury claim. When the plaintiff refused to cooperate with her illegal scheme to defraud I.C.B.C., the plaintiff alleges that the Defendant Angela Abbate, became angry and used the incident as a reason to seek revenge against the plaintiff by filing a fictitious sexual harassment claim. |
| 90. The plaintiff asserts that he denies the validity and substance of all of the Defendant Angela Abbate's claims of sexual harassment, and in particular, but not limited to, the plaintiff denies the Defendant Angela Abbate's sworn testimony and written complaint that he sexually molested, or that he spoke about sexually molesting, a seven, or in the alternative, an eight, or in the alternative, a nine year old girl in a Catholic school where the plaintiff taught. The plaintiff asserts that these statements, made and accepted as part of the Defendant Angela Abbate's testimony to the Defendant, the B.C. Human Rights Tribunal in June of 2000 by the Defendant Angela Abbate, for the sole purpose of defaming, slandering, and libeling the plaintiff. The plaintiff further alleges that the aforementioned statements were and are irrelevant to the Defendant Angela Abbate's contention that the plaintiff discriminated in employment against the Defendant Angela Abbate on the basis of her sex through sexual harassment. |
| 91. The plaintiff alleges that the Defendant (and sexual harassment complainant), Glenda Lee, was hired to work for the company ("Calvary") on a part time basis by the Defendant Jennifer Tannis on or about October of 1996, without the approval of the plaintiff, and who remained at Calvary Publishing Corp. solely on the basis of Jennifer Tannis's authority as part owner of Calvary Publishing Corp. The plaintiff further asserts that the Defendant, Jennifer Tannis offered the Defendant, Glenda Lee a full time position at Calvary Publishing Corp., on or about January of 1997, which decision the plaintiff asserts, he had no part in. The plaintiff further alleges that the Defendant Glenda Lee, seemed to be suffering from some apparently severe emotional instability which left her sufficiently vulnerable to be easily convinced by Jennifer Tannis and the Tannis family to participate in filing a false and fraudulent sexual harassment claim against the plaintiff on or about June of 1997. |
| 92. The plaintiff asserts that there are numerous, substantive inconsistencies between the original complaint that the Defendant Glenda Lee, filed with the BC Human Rights Commission on or about June of 1997, the Witness Statement provided by the Defendant, Heenan Blaikie on or about April of 1999 by the Defendant, Tonie Beharell, and the sworn testimony as paraphrased by the Defendant Tom Patch in his Reasons for Decision, which the Defendant the Defendant, Glenda Lee gave to the BC Human Rights Tribunal in June of 2000, including, but not limited to conflicting testimony as to when the alleged sexual harassment began. The plaintiff aserts that the Defendant, Glenda Lee stated in her original complaint filed with the Defendant, the BC Human Rights Commission on or about June 17, 1997, which was written in her own hand and signed by her, that "Sexual harassment commenced on the first day of work (on or about October of 1996) to the last day of employment {on or about April of 1997}." The plaintiff further asserts that Defendant Glenda Lee testified before the Defendant the B.C. Human Rights Tribunal, as paraphrased by the Defendant Tom Patch in his Reasons for Decision on or about June of 2000, that "She said that when she agreed to work full-time in January (1997), Mr. Tannis was still if the office and the atmosphere was good." The plaintiff further asserts that she testified before the Defendant the B.C. Human Rights Tribunal "....when Mr. Tannis was there--Mr. Robbins behaviour towards her consisted mostly of staring." The plaintiff alleges that this conflict is due to the fact that the Defendant Glenda Lee changed her story to accommodate the fact that the Defendant Mitchell Tannis, swore an affidavit that he did not witness any sexual harassment occurring. The plaintiff further alleges that the Defendant Glenda Lee's testimony before the Defendant the B.C. Human Rights Tribunal contradicts the testimony of the other complainants, as to whether the plaintiff engaged in sexual harassment of the Complainants, as to whether the plaintiff engaged in sexual harassment of the complainants prior to the Defendant Mitchell Tannis, leaving on or about February of 1997. |
| 93. The plaintiff asserts that the Defendant Glenda Lee testified before the Defendant, the B.C. Human Rights Tribunal, that the plaintiff allegedly perpetrated no less than eight specifically identifiable acts of sexual harassment towards some or all of the other Complainants and herself, with a frequency of "at least once a day". The plaintiff asserts that it is simply impossible for the plaintiff to have conducted the sheer volume of alleged harassment, given the limited amount of time he attended to the working environment of the Complainants. |
| 94. The plaintiff asserts that the Defendant Glenda Lee, filed an accusation of sexual harassment against a known friend to the plaintiff and part-time employee at Calvary Publishing Corp., Mr. Murray Cameron, who had come to work approximately 5 hours a day to supervise the administration area after the Defendant Mitchell Tannis left on or about February of 1997, and who at the time the complaint was filed--if you can believe this---was a 75 year old senior citizen. The plaintiff asserts that this claim was accepted on its face value, without proper investigation by the Defendant Christopher Finding and the Defendant, the BC Human Rights Commission. The plaintiff further asserts that the Defendant Glenda Lee's claim against Mr. Cameron for "staring at her body" was DISCONTINUED only when the Defendant the B.C. Human Rights Commission, was informed by medical personal-which information was presented by Glen P. Robbins who was acting for himself and for Mr. Cameron at that time---THAT SENIOR CITIZEN----75 YEAR OLD MURRAY CAMERON---WAS LEGALLY BLIND. The plaintiff Glen P. Robbins asserts that without equivocation--the Defendant Glenda Lee made specifically similar accusations against the plaintiff in her sexual harassment claim against him. |
| 95. The plaintiff asserts that he laid off the Defendant Glenda Lee prior to the end of her probationary period, due to the work performance of the Defendant Glenda Lee and the general lack of work for her in the administration department. |
| 96. The plaintiff alleges that the Defendant Glenda Lee was angry when she was laid-off from Calvary Publishing Coro., due to her poor work performance and a general lack of work in the administration, after the Defendant--Jennifer Tannis--who had hired her---had quit about March of 1997. A little coincidental wouldn't ya think? The plaintiff further alleges that the Defendant Glenda Lee is alluding to the true reasons for her lay-off on or about April of 1997, when she wrote in her claim to the Defendant- the BC Human Rights Tribunal: "However, I still feel that I was wrongly dismissed because I've been a hard worker and have completed everything that was my duty as well as assisting others in their duties. I can submit proof of my ability w/witnesses and referals {sic}." The plaintiff alleges that the Defendant Glenda Lee decided to go 'Allard' (sic) and get back at the plaintiff for her lay-off, by joining the plot to file sexual harassment complaints, which plot was aided and abetted by "one of my closest friends since childhood", the Defendant Jennifer Tannis. |
| 97. The plaintiff asserts that he denies the validity and substance of all of the Defendant Glenda Lee's claims of sexual harassment against the plaintiff. |
| 98. The plaintiff asserts that the Defendant (and sexual harassment complainant) Laura Dato, stated in her original complaint filed with the Defendant the BC Human Rights Commission, which was written in her hand, and signed by her and dated June 18, 1997, that "Sexual harassment Occurred whenever Glen Robbins was present" {I am not certain if that isn't a little Freudian compl(e)ment?} The plaintiff further asserts that the Defendant, Laura Dato testified before the Defendant the BC Human Rights Tribunal on or about June 2000, that "Every time she (the Defendant, Laura Dato) filed something in the filing cabinet, she would notice him (the plaintiff) staring at her...She filed every day, so this occurred five time a week." The plaintiff further asserts , that the Defendant, Laura Dato alleges that this harassment continued daily for approximately eight months, while she worked part-time for the Defendant Mitchell Tannis at Tannis Printing Ltd. The plaintiff further asserts that the Defendant Laura Dato alleged in her testimony to the Defendant the BC Human Rights Tribunal on or about June of 2000, as paraphrased by the Defendant Tom Patch in his Reasons for Decision, that at least four types of sexual harassment were perpetrated by the plaintiff on a daily or at least "two or three times a week" basis. The plaintiff alleges that since the Defendant, Laura Dato worked 2 hour each day after school, and part-time during the Summer of 1996, that he would have had to harass the Defendant almost continously during her hours of work, in order to achieve the alleged volume of sexual harassment, which the plaintiff asserts, is simply not possible. |
| 99. The plaintiff asserts that the Defendant Laura Dato, wrote in her original complaint to the Defendant, the B.C.Human Rights Commission that "When Glen worked as a salesperson in the same office as myself, I would notice him, turned around in his chair to face me, totally disregarding his work. "The plaintiff further asserts that the Defendant Laura Dato, in her testimony to the Defendant, the B.C.Human Rights Tribunal on or about June of 2000, as paraphrased by the Defendant Tom Patch in his Reasons for Decision, testified that the Plaintiff stared at her "Every time {she} filed something in the filing cabinet...She filed every day, so this occurred five times per week. The staring continued until Mr. Robbins moved his office upstairs in September of 1996. Mr. Tannis was working upstairs at the time." The plaintiff alleges that when the Defendant Laura Dato states that the plaintiff worked in the same office as the Defendnat Dato from February of 1996 until September of 1996, that she is lying, and has completely contradicted the Witness Statement provided by the Defendant Heenan Blaikie and the Defendants Tonie Beharell for the Defendant Lindsay Lyster dated on or about April 30, 1999 in which it is stated "At the time when the plaintiff "took control" of the company--on or about September 1996 Robbins, who had previously worked primarily in the upstairs portion of the office, began to come downstairs very frequently interacting with staff." The plaintiff asserts that he had only worked at a desk in the administration office for approximately two weeks in total, on or about February 1996, onwards. The plaintiff further alleges that these statements made by the Defendant Laura Dato, appear to have been concocted as some kind of explanation as to why the Defendant Mitchell Tannis did not see the virtually continuous sexual harassment that the plaintiff is alleged to have perpetrated upon allof the complainants from approximately February of 1996 until approximately February of 1997, in the full presence of their employer, the Defendant Mitchell Tannis. The plaintiff further alleges that this blatant fabrication is a further indication of the conspiracy which exists between the Tannis family, the complainants, and the Defendant Tonie Beharell to conceal the truth and to seek revenge against the plaintiff. |
| 100. The plaintiff alleges that the Defendant Laura Dato, was influenced by her parents who attended the same church in Burnaby as her parents, as well as the Defendant Sarah Clemente, Angela Abbate (her cousin) and Glenda Lee, to file a sexual harassment claim against the plaintiff. The plaintiff further alleges that it would have been relatively easy to influence the Defendant Laura Dato as she was the youngest of the complainants, and still a minor at the time that the sexual harassment claims were filed. The plaintiff further alleges that the Defendant Laura Dato, confessed to the plaintiff that sheh was "embarrassed" that her parents filed a false and fraudulent fire insurance claim in order to upgrade the kitchen in their family home and as a consequence, the plaintiff alleges the Defendant Laura Dato was not able to distinguish between right and wrong in such matters. |
| 101. The plaintiff asserts that the Defendant Laura Dato approached him on more than one occasion to ask if the plaintiff or the plaintiff's company would "sponsor" her in various beauty pageants. The plaintiff asserts that at no time didi he discuss or speak about posing for Playboy magazine with the Defendant Laura Dato. |
| 102. The plaintiff asserts that the Defendant Laura Dato was a part time employee for the entire time that she worked for the plaintiff, and that she was laid-off due to the nearly 50% reduction in daily sales volume and the corresponding reduction of wasteful work in adminstration. |
| 103. The plaintiff asserts that he denies the validity and substance of all of the Defendant Laura Dato's claims of sexual harassment against the plaintiff. |
| 104. The plaintiff asserts that during and after the time that the sexual harassment complaints were being filed by the Defendants Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee and Laura Dato, he was confronted by a number of third part individuals who had been specifically aware of the complaints, or had heard of the complaints made by the Defendants to the Defendant, the B.C. Human Rights Commission, and that these people had heard about the complaints from complainants, as well as the complaint masterminds and promoters Mitchell and Nadine Tannis, Joseph Daou and others. The plaintiff further asserts that as a consequence, he protested immediately to the agent for the Defendant the BC Human Rights Commission, who informed the plaintiff that there "was nothing that could be done" to silence such "rumour mongering". The plaintiff further alleges that a concerted effort on the part of the Defendants Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee, Laura Dato, Mitchell Tannnis, Nadine Tannis, and Joseph Daou, was made to damage the plaintiff's reputation and business, and to destroy the goodwill that existed between the plaintiff's business and the community. The plaintiff further alleges that the damage inflicted on the plaintiff by the aforementioned Defendants and others was exacerabated by the 19 month initial delay that was perpetrated by the Defendanta the B.C. Human Rights Commission when that body failed to expedite the processing of the complaints. |
| 105. The plaintiff alleges that the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, Christian Tannis and Joseph Daou, acting as T.E.G. Generation II did maliciously and wilfully begin to spread gossip about the sexual harassment complaints made by the Complainants against the plaintiff, within the community where the plaintiff worked and resided, from the date that the complaints were filed with the Defendant the B.C. Human Rights Commission, and specifically phone and write to clients and other business associates of the plaintiff and knowingly fabricated stories to these people that the plaintiff was twice bankrupt--which was ONLY true of the Defendant Mitchell Tannis, and completely UNTRUE of the plaintiff Glen P. Robbins who asserts that he has never been in bankruptcy nor ever applied for bankruptcy nor ever considered bankruptcy--convicted of fraud--which was NOT true of the plaintiff Glen P. Robbins who has never been accused of, or charged with, nor convicted of fraud either criminally or civilly. The plaintiff asserts that an example of this was the firm Marsh and McLennan and specifically their designate for the purchasing of advertising namely Ms. Connie Faulkner,and the plaintiff further alleges that the Defendants referenced to herein, did also spread lies, rumours and gossip about the plaintiff within the Roman Catholic Church and more specifically, The Knights of Columbus, in the hopes of damaging the reputation of the plaintiff. The plaintiff further alleges that the aforementioned Defendants, stood to gain financially from the defamation of the plaintiff's reputation and business, and by convincing the plaintiff's clients to move their business from Calvary Publishing Corp., to the aforementioned Defendant's new company, T.E.G. Generation II |
| 106. The plaintiff asserts that despite the well known difficulties that the Tannis Group of Companies experienced with the first sexual harassment complaint referred to herein on or about March 1996, and despite being provided with a written Sexual Harassment Policy created by the plaintiff, which contained explicit guidelines for dealing with sexual harassment, the Defendants Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee and Laura Dato, failed to make ANY claim of sexual harassment against the plaintiff for a period extending well over 18 months. The plaintiff alleges that the failure of the Complainants to report hundreds, if not thousands of alleged incidents of sexual harassment is a direct consequence of the fact that there never was any sexual harassment on the part of the plaintiff, or in the alternative, the Complainants made a conscious decision to withhold their complaints until such time as the plaintiff was of no further use to them and the Tannis family, or in the alternative, the Complainants did complain to their employers, the Defendants Mitchell and Nadine Tannis as well as Jennifer Tannis, who instructed them to 'hold' their complaints until such time as it became beneficial to the Tannis family to use the complaints against the plaintiff for personal advantage. The plaintiff further asserts that if the Complainants had been sexually harassed, then the Complainants would have had an obligation to mitigate any damage that they allegedly suffered by following the company's Sexual Harassment Policy and advancing their complaints to a manager or owner of the company within 1 week of any incident, as dictated in the Sexual Harassment Policy. The plaintiff further asserts that not one complaint of sexual harassment was ever brought to his attention, or to the best of the plaintiff's knowledge, to anyone else's attention at Tannis Printing Ltd. or Aurora-M.T. Publications, or Calvary Publishing Corp.,other than the complaint against Jacob Jones. |
| 107. The plaintiff asserts that during the approximately 18 months that sexual harassment was alleged to have occurred, there were no fewer than 10 employees other than the complainants working the the same small office area from time to time, yet there were no independent corrobative witnesses that supported any of the complaints of the complainants, with the exception of Joseph Daou, whose testimony was given "no weight" by the Defendant Tom Patch of the Defendant, the B.C. Human Rights Tribunal in his Reasons for Decision. The plaintiff further asserts that, although there are no independent corrobative witnesses to the sexual harassment, there is a great deal of alleged corroboration among the complainants themselves, who testified repeatedly they they observed the plaintiff harassing the other complainants on countless occasions, in full view of all of the other employees who were in the room with them, which the plaintiff alleges, reveals unexplained differences between the stories told by the complainants, and the apparent facts. |
| 108. The plaintiff asserts that the contention of all of the complainants that sexual harassment occurred on a "Daily & hourly basis" as witnessed by "Every worker at Calvary Publishing Corp." according to the Defendant Jennifer Tannis, seems exceedingly unlikely given the statement made by Professor Zemans, when sitting as a Board of Inquiry in Ontario, in Graesser v. Port (1983), 4 C.H.R.R.D/1569 at D/1572: "...one rarely encounters the situation where the offence or alleged offence takes place in the open, and therefore can be proven through eyewitness testimony. That is, rarely will one sexually harass another in full public view. Rather, these events usually take place behind closed doors or with no witnesses being present." The plaintiff further alleges that complainants were so over eager to develop a convincing story, that they have created an impossible situation in which they alleged constant harassment of 5 or more individuals taking place in a room filled with witnesses, but in which only the complainants are ultimately aware of each other's harassment. |
| 109. The plaintiff asserts that he treated all members of the staff, whether they were male or female, in exactly the same way. The plaintiff further asserts that there is no possible way that any behaviour attributed to the plaintiff could be construed as being discriminatory, based on sex. |
| 110. The plaintiff asserts that the Defendant Angela Abbate had been promoted to a co-manager of administration along with the Defendant Sarah Clemente, on or about March of 1997, and that this obliged, or ought to have obliged, each of the Defendants to step forward with any knowledge that they may have had of alleged sexual harassment complaints by other complainants, most specifically Jennifer Tannis, Glenda Lee, and Laura Dato. The plaintiff further alleges that, as managers of Calvary Publishing Corp., the Defendant Sarah Clemente and Angela Abbate, had a duty to interrupt or at the very least mitigate any damage which the plaintiff was allegedly causing those Defendants. The plaintiff alleges, that the Defendants Angela Abbate and Sarah Clemente did not follow the company's Sexual Harassment Policy, and that this is further evidence that there was no sexual harassment taking place, or in the alternative, that a conspiracy of revenge was being prepared to destroy the reputation of the plaintiff. |
| 111. The plaintiff alleges that the Defendant Joseph Daou, solicited Kimberley Corbett, a part-time telemarketer who was hired in the spring of 1997, to file a fraudulent sexual harassment complaint against the plaintiff on or about June of 1997. This solicitation was witnessed by a third party employee named Mary Gillis of Calvary Publishing Corp., who later contacted the plaintiff, and revealed the nature of the conserations and solicitation. The plaintiff asserts that Ms. Corbett stated in front of the witness, that there was in fact, no sexual harassment, and that the Defendant, Joseph Daou, did in fact state that he knew this to be true, and that his adoptive father and mother, the Defendants Mitchell and Nadine Tannis, and the other complainants also knew that there was no sexual harassment, but that the complainants intended to file the complaints anyway in order to exact revenge on the plaintiff for the plaintiff's lawsuit which had been filed against the Defendant's Mitchell and Nadine Tannis, and for other various reasons. The plaintiff further asserts that Ms. Corbett initially agreed to go along with other complainants and did file a sexual harassment complaint, but later withdrew her complaint, or in the alternative, refused to file a complaint because, the plaintiff alleges, she knew the complaint to be false, or in the alternative, knew that there was a witness to her conversation with the Defendant Joseph Daou, which could result in her risking a citation for perjury. The plaintiff further alleges that this incident provides evidence that the Defendant Joseph Daou actively participated in the organization of the sexual harassment complaints that were filed with the B.C. Human Rights Commission. |
| 112. The plaintiff alleges that the Defendant Mitchell Tannis on or about the spring of 1997 did confront the plaintiff outside the plaintiff's office and threaten the plaintiff that "something bad was going to happen" {to the plaintiff) if he (the plaintiff) did not provide $50,000 cash within 7 days. The plaintiff asserts that he did not pay the blackmail, and shortly thereafter filed a lawsuit against the Defendants Mitchell and Nadine Tannis. |
| 113. The plaintiff alleges that he was again confronted by the Defendant Mitchell Tannis in a Coquitlam hotel lobby in the spring of 1999 where Mitchell Tannis indicated to the plaintiff that his problems with the B.C. Human Rights Commission could be made to "go away" for $50,000 cash. The plaintiff asserts that he told the Defendant Mitchell Tannis that it was "a fraud(ulent) case" and the Defendant Mitchell Tannis replied that "the fix was in" and that "Celso" {Boscariol} and his partner "Riva" {Hira} of Watson Goppel Moledy were connected to the Attorney General's office and the B.C. Human Rights Commission, and "would make sure the plaintiff was convicted." |
| 114. The plaintiff alleges that the Defendant Mitchell Tannis wrote and widely distributed a long letter in which he libeled and defamed the reputation of the plaintiff. The plaintiff further alleges that the letter was sent to friends and associates of the plaintiff within the business community and church that the plaintiff attended. |
| 115. The plaintiff asserts that he and Calvary Publishing Corp., were initially introduced to M.A.D.D. Canada in December 1996. The plaintiff alleges that after he and the Defendant Mitchell Tannis had parted ways, the Defendant Mitchell Tannis contacted M.A.D.D. Canada on or about the summer of 1998, who had become a client of Calvary Publishing Corp., and who had signed and duly authorized contracts for business with Calvary Publishing Corp., and the plaintiff alleges, that the Defendant Mitchell Tannis did seek to convince M.A.D.D. Canada that the plaintiff's company was acting in bad faith, or in the alternative, the plaintiff alleges that the Defendant Mitchell Tannis was aware that M.A.D.D. Canada had initially entered into a fraudulent agreement with the plaintiff and later used this knowledge to influence M.A.D.D. Canada into embarking on a litigable public relations campaign against the plaintiff and the plaintiff's company. |
| 116. The plaintiff alleges that he provided the Defendant the B.C. Human Rights Commission, through their designate, the Defendant Christopher Finding, with sufficient bona fide evidence in the form of affidavits from eye witnesses and other documentation from the very beginning of this matter which should have raised some very serious questions regarding the validity and merit of the sexual harassment claims made against the plaintiff by the Defendants Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee and Laura Dato. The plaintiff further alleges that the Defendant the B.C. Human Rights Commission's negligence in failing to recognize this deficiency of merit, did therefore knowingly and with malice aforethought purposely damage the plaintiff's reputation, or in the alternative, allowed the plaintiff's reputation to be damaged. The Defendant the B.C. Human Rights Commission did cause harm to the plaintiff's reputation through its negligence, and the plaintiff further alleges that it took no action, nor did it perform sufficient and reasonable due diligence, given the massive potentiality for damage being caused to the plaintiff, and therefore did abandon any opportunity to mitigate the damage done to the plaintiff's person, reputation and business prospects. The plaintiff asserts that the Defendant the BC Human Rights Commission ought to have:
a. thoroughly investigated and dismissed the sexual harassment complaints of Jennifer Tannis, Sarah Clemente, Angela Abbate, Glenda Lee and Laura Dato against the Respondent, Glen Robbins (the plaintiff herein), for being without merit or added the Defendants Mitchell Tannis, Nadine Tannis and Jennifer Tannis and Tannis Printing Ltd. as Respondents, and
c) ensured an expeditious hearing of the sexual harassment complaints against the plaintiff within 90 day of the filing of the complaint, and
d) allowed the plaintiff to discover the complainants pursuant to the Rules of the Court for the Province of British Columbia within 90 days of the complaint. |
| 117. The plaintiff alleges that the Defendants Chrisopher Finding and the BC Human Rights Commission were faced with the difficulty of reconciling the fact that the parents of the Defendant Jennifer Tannis were also the owners, employers and potential Respondents to her claims of sexual harassment during the months that the plaintiff was an employee of Tannis Printing Ltd. The plaintiff further alleges that the Defendants Christopher Finding and the B.C. Human Rights Commission failed to recognize the daily and continuous presence of the Defendant Mitchell Tannis, and the frequent presence of the Defendant Nadine Tannis, both of whom were potential bona fide witnesses to the alleged sexual harassment by the plaintiff. The plaintiff therefore alleges that the Defendants Christopher Finding and the B.C. Human Rights Commission 'conveniently' and for their own purposes ignored the existence and presence of the Defendants Mitchell and Nadine Tannis so that they could avoid the difficulties inherent in naming the parents of a Complainant to be Respondends to a complaint, which actions the plaintiff alleges were prejudicial to the defense of the claim. |
| 118. The plaintiff asserts that he did contact the office of the Defendant the Ministry of Attorney General of B.C., the Defendant Ujjal Dosanjh on or about the January of 2000, to request that an investigation be launched into the plaintiff's allegations of fraud by the complainants in his sexual harassment case. The plaintiff further asserts that the office of the Defendant, the Ministry of Attorney General of BC, the Defendant Ujjal Dosanjh on or about the Fall of 1999, did say that he 'might re-examine how the {B.C. Human Rights Tribunal} could better serve British Columbians', but subsequently failed to do so. |
| 119. The plaintiff alleges that during the period of time between March 1996 until November 1996, the Defendant Mitchell Tannis asked the plaintiff who worked as an employee/consultant at that time, to speak to the plaintiff outside the offices of the Tannis Group of Companies, later Aurora-M.T. Publishing, on at least 10 separate occasions at which times the Defendant Mitchell Tannis talked about his sexual past and his sexual prowess. The plaintiff asserts that the Defendant Mitchell Tannis spoke to the plaintiff about his use of prostitutes and preferences for women of colour. The defendant Mitchell Tannis always cautioned the plaintiff regarding these conversations to never speak of these matters in front of his wife, the Defendant Nadine Tannis, who was extremely jealous, and who according to the Defendant Mitchell Tannis would fly into fits of rage when she became jealous of him. The plaintiff alleges that he found these conversations to be profoundly disturbing and upsetting, and that these conversations constitute sexual harassment of the plaintiff by the Defendant Mitchell Tannis. |
| 120. The plaintiff alleges that the Defendant Nadine Tannis during the period of time between March 1996 until November 1996, asked to speak to the plaintiff allegedly about business, at the coffee shop near her offices at 4544 Hastings Street on at least 10 separate occasions, where she would talk of her sexual past and the difficulties that she and the Defendant Mitchell Tannis had in their marriage because of his infidelity to her, his consumption of alcohol and illegal recreational drugs, and his abuse of their children. The Defendant Nadine Tannis always cautioned the plaintiff to never speak of these matters in front of her husband the Defendant Mitchell Tannis as he was extremely jealous and possessive of her. The plaintiff alleges that he found these conversations to be profoundly disturbing and upsetting, and that these conversations constitute sexual harassment of the plaintiff by the Defenant Nadine Tannis. |
| 121. The plaintiff asserts that he attempted to file a sexual harassment complaint against the Defendants Mitchell Tannis, Nadine Tannis, Jennifer Tannis, and Sarah Clemente in the spring of 1997 and was denied the opportunity for a hearing by the Defendants Christopher Finding and the BC Human Rights Commission because, the plaintiff alleges, he was an employer, when in fact the plaintiff alleges, he was an employee at the time that the alleged sexual harassment occurred against him.
The plaintiff further alleges that he was denied his constitutional right to have his complaint heard as a consequence of the prejudice of the Defendant the B.C. Human Rights Commissions against male complainants. |
| 122. The plaintiff asserts that the disbarment of his attorney, Mr. Motiuk, came as a complete surprise to the plaintiff, who had less notice of this than did the Defendant the B.C. Human Rights Tribunal, who acknowledged receiving a letter from Mr. Motiuk testifying to this fact, dated on or about December 10, 1999. The plaintiff further asserts that he did not receive his file from Mr. Motiuk until approximately the first week of March 2000. The plaintiff further asserts that documents sought by counsel for the complainants were either lost by the Defendant, the B.C. Human Rights Commission, or in the alternative, misappropriated in actions that are documented herein, or in the alternative, remained in the possession of the Defendant Mitchell Tannis and the Tannis family, or in the alternative, were lost when they were moved following the closure (without notice) of Mr. Motiuk's law practice. The plaintiff further asserts, that he had none of the necessary legal documents to forward to the Complainants and their legal counsel, and was at a complete loss as to how to proceed. The plaintiff further asserts that counsel for the Complainants made no submission to the Defendant the B.C. Human Rights Tribunal regarding the issue relevance of the requested documents, and as a consequence, the Defendant Judy Parrack, designate of the Defendant the B.C. Human Rights Tribunal, submitted her own reasons on behalf of the complainants in her Reasons for Decision dated April 25, 2000 which action given the circumstances, indicates a biased and preferential treatment of the complainants by the Defendant, the B.C. Human Rights Tribunal at the expense of the plaintiff and his right to a fair hearing of the facts. |
| 123. The plaintiff alleges that when he initially responded to the complaints of the Defendants Jennifer Tannis et al, he questioned the Defendant Christopher Finding as to who was paying the Complainant's legal fees. The Defendant Christopher Finding, the plaintiff asserts, indicated that a lawyer was provided 'free of charge' to the Complainants. When the plaintiff asked the Defendant Christopher Finding if the plaintiff would also be receiving a lawyer 'free of charge', the Defendant Christopher Finding told the plaintiff that "Employers are not eligible for legal aid." This, the plaintiff further alleges left the plaintiff with very limited resources to mount a legal defense. The plaintiff further alleges that the subsequent disbarment of the plaintiff's legal counsel further damaged the plaintiff's ability to defend himself. The plaintiff asserts that while he has some experience with legal matters, the plaintiff admits that he has little knowledge pertaining to adminstrative law. The plaintiff further asserts that he did not have a good understanding of how the Tribunal process works, nor did the plaintiff have a clear understanding of the relationship between the Defendant, the B.C. Human Rights Commission and the Defendant, the B.C. Human Rights Tribunal. The plaintiff therefore alleges that by shunning his requests for legal assistance and ignoring his B.C. Supreme Court (the higher jurisdiction) Writ of Summons and Statement of Claim pursuant to the Rules of Court, and by proceeding with the hearing ex parte, the aforementioned Defendants ultimately contributed to the complete abrogation of the plaintiff's right to a fair hearing with the benefit of legal counsel in a forum deemed to be 'quasi-criminal'. |
| 122. The plaintiff alleges that, due to circumstances which were beyond his knowledge and control, his lawyer, John Motiuk, had apparently stopped providing an effective defense for the plaintiff on or about April of 1999 due the plaintiff alleges, to actions that were being taken against Mr.Motiuk in unrelated matters, which ultimately lead to Mr. Motiuk's disbarment in 1999. The plaintiff further asserts that he had no advanced knowledge of the John Motiuk disbarment. The plaintiff alleges that the fact that Mr. Motiuk did not file submissioins on the issue of joinder of the complainants into a single hearing prior to April 8, 1999, and failed to respond to later requests for documents during the summer of 1999, indicates the plaintiff was no longer being effectively represented by counsel. The plaintiff alleges that the Defendant the B.C. Human Rights Tribunal, despite knowledge that the plaintiff's counsel had been disbarred, did not offer the plaintiff any leniency with regards to scheduling of the hearings, and did refuse to assist the plaintiff in obtaining counsel via legal aid, despite the plaintiff's assertion that he could not afford to hire another lawyer. |
| 123. The plaintiff asserts that the Defendant the B.C. Human Rights Commission notified the plaintiff via letters submitted to his then attorney, John Motiuk, dated on or about March 26,1998 and March 31, 1998, that they had referred the first of the Complainants, the Defendant Jennifer Tannis, to the Defendant the B.C. Human Rights Tribunal for a hearing which was set to commence January 4, 1999, approximately 19 months after the initial complaint was filed on or about June 13, 1997. The plaintiff further asserts that he is not aware of any useful actions taken by the Defendant the B.C. Human Rights Commission, during this intitial 19 month delay, and was never contacted by them during this time. The plaintiff further asserts that then counsel for the complainants, the Defendant Lindsay Lyster further delayed the process by requesting an adjournement of the hearing scheduled for January 4, 1999, on or about December 14, 1998, which hearing was subsequently rescheduled for November 22, 1999, for a total delay of approximately 29 months from the date of the filing of the first sexual harassment complaint. The plaintiff further asserts that his lawyer, John Motiuk requested an adjournement of the hearing scheduled for November 22, 1999 by letter dated on or about November 16, 1999 for his own purposes and did not consult the plaintiff about this. The plaintiff therefore asserts that he had no part in causing the initial 29 month delay in proceeding with the hearing of these complaints, which delay caused the plaintiff damage to his reputation, extreme anxiety, loss of self-esteem, loss of business opportunities, and damage to his company profits due to the ongoing slanderous, libelous, and vexatious actions of the complainants and the Tannis family and others, who took full advantage of the delay. |
| 124. The plaintiff alleges that, had the Defendants the B.C. Human Rights Commission and the B.C. Human Rights Tribunal proceeded in a timely manner to act on the sexual harassment complaints of the complainants, and to provide a fair and timely hearing, then there would have been adequate time for the issues to have been resolved prior to Mr. Motiuk's disbarment. The plaintiff therefore alleges that the initial delay of 19 months and the further delay of 10 months resulted indirectly in the plaintiff's loss of access to legal counsel due to the disbarment of the plaintiff's lawyer. The plaintiff alleges that the same delay resulted in undue financial hardship because of the plaintiff's decloine in business income, due to the slander and libeling of his name in the business community, and due to the inability of the plaintiff to focus on business matters because of the pending sexual harassment complaints, ultimately lead to the plaintiff being unable to afford to retain another lawyer for his hearing in June of 2000. |
| 125. The plaintiff asserts that the Supreme Court of Canada has determined that it is reasonable for a Respondent in sexual harassment claims to expect the complaint to be heard within 90 days of the complaint first being filed, as the Respondent in such matters has a right to an expeditious hearing. The plaintiff asserts that the complaints against him were delayed 29 months, from the time that the first complaint was filed on or about June 13, 1997 untill November of 1999, allowing the Defendants including the Tannis family and the sexual harassment complainants and others sufficient time to completely discredit and damage the reputation of the plaintiff, notwithstanding the eventual outcome of their complaints, and notwithstanding any additional delays beyond that time which was in part the responsibility of the plaintiff's former lawyer John Motiuk, who was disbarred due to unrelated circumstances on or about December of 1999. The plaintiff further alleges that the notion of reverse onus, the that that a hearing is not provided expeditiously, and the fact that the complainants received FREE legal counsel indefinitely (sic), are a breach of the plaintiff's constitutional entitlement to equal justice. |
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