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Court File No.: C-1290-03 BETWEEN: Plaintiffs Defendant I, PETER RINGROSE, of the Township of Wellesley, and Province of Ontario, MAKE OATH AND SAY AS FOLLOWS: 1. I am one of the plaintiffs in this action and as such have knowledge of the matters hereinafter deposed to. 2. I am the executive director of the Children's Aid Society of the Regional Municipality of Waterloo also known as Family and Children's Services of the Waterloo Region. 3. On Thursday, January 27, 2005, Mr. Justice Reilly granted to me and to Mr. Duane Boles, the other plaintiff in this action, a permanent injunction restraining Aneurin Ellis from publishing, circulating, distributing, communicating or otherwise transmitting libelous or slanderous words or allegations against the plaintiffs or the Children's Aid Society of the Regional Municipality of Waterloo also known as Family and Children's Services of the Waterloo Region or any of its staff members. A true copy of the judgment which was granted in the presence of Mr. Ellis is attached hereto as Exhibit "A" to this my affidavit. 4. A true copy of the reasons of Justice Reilly given in the presence of Mr. Ellis is attached hereto as Exhibit "B" to this my affidavit. 5. On or about June 20, 2005, I became aware that Mr. Ellis had, on or about the 8th day of June, 2005, sent an email to the Prime Minister referring to the Family and Children's Services of the Waterloo Region as the "Children's Gestapo (FCSWR) of New Berlin (Kitchener)". In that email, he alleged that Family and Children's Services had subjected his family to "criminal harassment" and compared Family and children's Services to "La Cosa Nostra". In that same email, he alleged that the Family and Children's Services operates in complete secrecy very much like the German Gestapo during the Second World War. In that email, he also alleged that Mr. Kevin Chalk, who is the president of the board of directors and a police officer were guilty of illegal activity and suggested that his actions were similar to that of the Nazi Gestapo. 6. Mr. Ellis has falsely suggested that I am the executive director of an organization with operates in complete secrecy very much like the German Gestapo and, further, suggests that I, in collaboration with Mr. Chalk, are in charge of a "very secretive charitable organization with power to enter private residence without warrant and apprehend without court order, create a situation that is unbearable, oppressive, and conducive to corrupt and criminal abuse of power and authority of otherwise a legitimate and democratically elected government". 7. He further suggests that the arrangement between me and Mr. Chalk has "lead (sic) to unchecked abuse of his family and countless other families in the Region". 8. I consider these statements false, defamatory and a flagrant breach of the injunction granted by Justice Reilly on January 27, 2005. 9. A true copy of that email is attached hereto as Exhibit "C" to this my affidavit. 10. I was advised by a member of my staff that Mr. Ellis was handing out the documents which are attached hereto as Exhibit "D" to this my affidavit at the Frederick Street court house on July 26, 2005. All of the derogatory allegations set forth in Mr. Ellis' emails are false and untrue and I am offended by them. 11. A contempt motion against Mr Ellis was originally returnable August 24, 2005 and adjourned to September 7, 2005 at Mr. Ellis' request to permit him to file documents in response to the motion record which was filed and served personally upon him. 12. The motion was heard by Justice Fedak on September 7, 2005 at which time Justice Fedak made an order in accordance with the endorsement attached as Exhibit "E" hereto. A copy of Justice Fedak's reasons were ordered in early March, 2006 but not delivered to my lawyer's office until June 4, 2006. Attached hereto as Exhibit "F" is a true copy of Justice Fedak's reasons. 13. Justice Fedak made the following finding:
14. Justice Fedak then went on as follows:
15. Mr. Ellis did send the required retraction and Mr. Boles and I were hopeful that that would be an end to Mr. Ellis' libelous actions. 16. In January, 2006, I became aware that Mr. Ellis attended and testified before a committee of the Provincial Parliament in December, 2005. A copy of Mr. Ellis' testimony is attached hereto as Exhibit "G" to this my affidavit. 17. Subsequently, Mr. Ellis published on an internet website and sent this email attached as Exhibit "H" to this my affidavit to several individuals at Family and Children's Services of the Waterloo Region as follows:
18. The website link contained in Mr. Ellis' email goes to a website for Canada Court Watch Report and opens a newsletter entitled "Waterloo Children's Aid worker Commits Perjury". Attached hereto and marked as Exhibit "I" to this my affidavit. 19. Mr. Ellis' email once again portrays the Family and Children's Services of the Waterloo Region as a lawless entity and suggests that Family and Children's Services is guilty of child kidnapping, drugging, extortion, blackmail, fraud, perjury, torture and even murder. He refers to Family and Children's Services as a "filthy criminal organization masquerading as a righteous child protection institution". 20. This is the second contempt of Justice Reilly's judgment. 21. I make this affidavit in support of a motion to have Mr. Ellis incarcerated for a period of six months. Mr. Ellis has not paid the previous costs award he has been ordered to pay pursuant to the Judgment of Justice Reilly and the Order of Justice Fedak. /signed/ PETER RINGROSE SWORN before me at the /signed/ A commissioner etc.
Kimberly Ann Anger, a Commissioner, etc., 
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