The Three Smoking Guns · Simetic Chapter
Jerry L. Goldberg · in his own voice
An audio recording in David Simetic's possession captures the Defendant Jerry L. Goldberg admitting to forging bank statements in connection with the Estate of Ivan Valentich. Chain of custody documented in the 328-page binder. Never heard by the Law Society in ten years of complaints.
Norman Groot · Peel Regional Police
Norman Groot, then a serving Peel Regional Police officer, was convicted in 1999 of obstruction of justice and fabrication of evidence. This conviction is the legal fact that establishes the Groot-family pattern of obstruction at the heart of the cross-chapter bridge.
Search CanLII →Law Society of Ontario · systematic dismissal
Every complaint dismissed as “frivolous” within two to four weeks. No audio reviewed. No forged document examined. No witness interviewed. Foundation of the Track B Judicial Review component and of the Charter s. 7 argument that unreviewed dismissal of proven misconduct is unconstitutional.
The Three-Track Litigation Plan
Headline Quantum
CAD $132,000,000 recommended floor (Exhibit 17-SIMETIC Damages Multiplier Schedule, 27 April 2026). This replaces the provisional CAD $60M figure from the Three-Track Litigation Plan, which was flagged "TBD · awaiting calculation." The new number applies the same per-perpetrator × years × crimes methodology used for the Ceylan chapter — 20 years of estate fraud, 4 individual perpetrators (Goldberg, Fullerton, Norman Groot, Emily Groot), 5 institutional defendants (LSO, Shibley Righton, Peel Regional Police, Office of the Chief Coroner, Ontario SCJ/LECA), Whiten punitives, Ward Charter damages, aggravated damages for 10×10 LSO dismissal pattern, plus RICO enhancement. This is a floor, not a cap — final judgment may exceed it.
→ Read Exhibit 17-SIMETIC · full damages calculation (PDF)
Unified Trifecta recommended floor: CAD $642,000,000+ across all three chapters, subject to upward revision at trial.
Evidence Hub Materials
The following core materials are already on the record; they will be tendered as exhibits at appropriate stages of proceedings:
| Artifact | Location |
|---|---|
| Dave Simetic · Chapter 3 case page | genspark_mirror/nxffhryi.gensparkspace.com/dave-simetic.html |
| Chapter 3 skeleton (cross-references and FOI status) | genspark_mirror/nxffhryi.gensparkspace.com/dave-simetic-chapter.html |
| Three-Track Litigation Plan (20 Jan 2026) | genspark_mirror/.../DAVE_SIMETIC_THREE_TRACK_LITIGATION_PLAN.html |
| FOI request package | genspark_mirror/.../DAVE_SIMETIC_FOI_REQUEST_PACKAGE.md |
| Statement of Claim viewer ($60M SOC) | genspark_mirror/.../dave-simetic-motion-viewer.html |
| 328-page investigation binder | To be tendered under Rule 30.02, Rules of Civil Procedure |
Evidence · Embedded on the Public Record
Standing exhibit library for the David Simetic chapter of the Windsor Justice Trifecta. Everything below is loaded directly on this page. Judge, journalist, whistleblower, LSO investigator, or member of the public can view it without another click.
🎥 Audio on the public record
Recording of Francesco Longo’s exchange with LAO worker Ashley Dale in which she confirms she has been told there is no order to provide Francesco with anything. Core evidence of the Legal Aid Ontario denial pattern that runs across every Windsor Justice Trifecta chapter (Longo, Simetic, Ceylan).
Direct download · M4A · 4.6 MB
📄 Simetic-Specific Filings & Exhibits
Simetic’s share of the Mareva floor and per-defendant/per-year/per-crime compound liability schedule.
Open exhibit → · PDF
Ontario signing-ready affidavit of David Simetic in support of the Windsor Justice Trifecta Notice of Civil Claim.
Open affidavit → · PDF
Unified Notice of Civil Claim addendum that adds David Simetic as plaintiff alongside Francesco Longo and the Estate of Raffi Ceylan.
Open addendum → · PDF
📷 Corroborating imagery
For Francesco Longo’s Ceylan-side evidence hub see Raffi Ceylan · Evidence on the public record. For the full filing package see the Ontario SCJ Toronto package.
Groot Family Cross-Chapter Bridge
| Defendant | Year | Matter | Link |
|---|---|---|---|
| Norman Groot | 1999 | Peel Regional Police · obstruction-of-justice CONVICTION · R. v. Groot | Simetic chapter (this page) |
| Dr. Emily Groot | 2016 | Ontario Chief Coroner · Raffi Ceylan death investigation · no strychnine test · 3 recorded calls with Lucy Ceylan | Ceylan chapter (/raffi) |
The family relationship between the two Defendants, combined with the documented misconduct by each in institutional roles twenty-seven years apart, is the foundation for the joint-enterprise criminal organization claim pleaded under s. 467.1 of the Criminal Code, R.S.C. 1985, c. C-46, against all 24 Defendants jointly and severally.
Cross-Links to the Unified Claim
- Homepage · Canadian People's Trust
- Raffi Ceylan evidence page (Chapter 2)
- Full 24-filing Ontario SCJ Toronto package (Chapters 2 + 3)
- NOCC Pass 5 + Pass 6 Addendum (adds Simetic as plaintiff)
- Mareva Floor Clarification Filing #01C
- Simetic Affidavit #05C · Signing-Ready
- Filing #23 Interim Relief Motion
- Perpetrators registry (Longo chapter)