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MOTION TO ONTARIO SUPERIOR COURT OF JUSTICE (DRAFT)

Author:ÌÆì¿Õé Date:2010-07-26 16:34:27 Readers:98 reads

Summary

Court File No. : CV-09-8090-00Cl

ONTARIO SUPERIOR COURT OF JUSTICE
( Toronto Region )

BETWEEN

Weizhen Tang

The applicants

And

Jeffrey Thomson, W. David Wilson, James E. A. Turne, David L. Knight, ONTARIO SECURITIES COMMISSION
The Respondent

IN THE MATTER OF THE SECURITIES ACT,
R.S.O. 1990, c. S.5, as amended
AND

IN THE MATTER OF OVERSEA CHINESE FUND LIMITED
PARTNERSHIP, WEIZHEN TANG AND ASSOCIATES INC.,

WEIZHEN TANG CORP., and WEIZHEN TANG

NOTICE OF MOTION
Section 127

Respondent WEIZHEN TANG is making a motion to the Ontario Superior Court of Justice (Toronto Region ) on August 6, 2010, at 9:30 a.m., or as soon after that time as the motion can be heard, at 361 University Ave, Toronto.

PROPOSED METHOD OF HEARING: The motion is to be heard orally.

THE MOTION IS FOR:

(a) An order to stop defamation, libel and slander of character and name
(b) An order to stop racist and discrimination
(c) An order to ask OSC pay defamation, slander of character and name damage and business loss of 70 million Dollars
(d) An order to stop OSC from destruction of defense and justice
(e) An order to stop OSC from destruction of live, small business and economy and government
(f) An order to stop OSC from harm to investors and public
(g) An order to investigate OSC and its staff detrimental effects
(h) An order to restore free market economy and our private financial business
(i) An order to unfreeze Oversea Chinese Fund Limited Partnership account and stop OSC IB directions
(j) An order permitting Weizhen Tang (“the Respondent”) to trade in all financial markets, including securities markets
(k) An order permitting Weizhen Tang (“the Respondent”) to trade on his own behalf, on behalf of all accredited investors
(l) An order permitting Weizhen Tang (“the Respondent”) to trade on behalf of all Investors who have signed consents and oversea /offshore Investors;
(m) An order permitting Weizhen Tang (“the Respondent”) to trade on behalf of all investors outside of Ontario and non-Canadian residents
(n) Such further relief as to Ontario Superior Court of Justice may seem just.

THE GROUNDS FOR THE MOTION ARE:

(a) OSC charges to Weizhen Tang as running Ponzi schemes are baseless, totally wrong ,false, racist and discrimination and it is a defamation, destructive and devastating which needs to stop immediately
(b) Orders to cease trade are pre-punishment, detrimental and destructive and punish to private business and private investors and innocent people which needs to stop immediately
(c) OSC’s investigation has lasted over one year without finding anything meaningful evidences and no evidence of fraud, Weizhen Tang appeal for summary judgment
(d) Weizhen Tang made great contributions to the North American financial industry, to Canadian economy and to Canada, appeal for justice
(e) An order initially made on March 17, 2009, and extended from time to time since then, the Respondent was ordered to cease all forms of trading is against investors’ will and hurting business, investors, economy and public and government, destructive to everyone including OSC need to stop immediately
(f) the Respondent is one of the greatest investors in the world, is a great asset to investors, to the industry, to the economy and to the country and to the world.
(g) the Respondent has the best investment skills and system in the world and has lot of experience to trade successfully in all markets, including the foreign currencies market;
(c) it is the clear wish and will of most of investors that Weizhen Tang be permitted to trade on their behalf and on behalf of the public; all investors are aware of the risk attendant upon investing, and are aware of the charges currently facing the Respondent at the Ontario Securities Commission and the Crown Attorney office;

(e) the Respondent’s compliance with all regulatory standards would be ensured by supervision carried out by either a registered senior portfolio manager or public, and OSC in its discretion;

(f) the Respondent will undertake to make all of his trading transparent, and to provide full accountings of same at regular intervals to the Ontario Securities Commission, to the investors, and to the supervisor, should the cease-trade order currently in place be lifted on terms;

(g) the existing cease-trade order functions as a penalty and discrimination before trial;

(h) a return to trade would permit the Respondent to continue his business and begin to recover the losses investors incurred in the financial market when the Respondent was previously managing their respective investment accounts;

(j) such further grounds as the Ontario Superior Court may permit.

THE FOLLOWING DOCUMENTARY EVIDENCE will be used at the hearing of the motion:

(a) Awards and Contributions from all governments
(b) Books, My buffettian Way to the Wealth and Weizhen Tang Phenomenon
(c) Affidavit of Weizhen Tang, sworn August 3, 2010;
(d) lawyers letters to Weizhen Tang
(e) Investors petition and supporting letters and emails
(e) Investors letters to OSC and to Weizhen Tang
(f) Consent-forms executed by investors;
(g) Trading records and trading videos
(h) Pleadings and proceedings herein;

such further material as the Ontario Superior Court may permit.

Date: August 3, 2010

the Respondent

Weizhen Tang
19 Robinter Drive, North York
Ontario, Canada

TO:
ONTARIO SECURITIES COMMISSION
1903 - 20 Queen Street West, Box 55
Toronto, Ontario M5H 3S8

Matthew Boswell (
Hugh Craig
416.593.8259
416.593.2319 (fax)
Lawyers for the applicant,
Ontario Securities Commission

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