R v Le Blanc — Defence Presentation for Counsel — June 23, 2026 — OFFLINE

R v Le Blanc

Ontario Court of Justice, Kitchener | Information 4411-998-26-44101707-00

Charter Breaches

000

BAC mg/100mL

0 km/h

Vehicle Speed

17h20m

s.10(b) Denial

False Documents

Camera Angles

Badge Demands

Tesla Security Recording — March 15, 2026 — 9 Cameras — 19m17s

The Scene — Engine off. No keys. Laptop mounted to steering wheel.

The accused was working on a laptop physically mounted to the steering wheel with a bracket and brace at 92 Oxford Crescent — his regular daily work location. Vehicle: 2020 Tesla Model Y (registered owner: Monica Cosby).

The arresting officer confirmed the laptop at ~14:42:14: "Put your laptop down."

Tesla telemetry: GPS stationary, 0 km/h, odometer unchanged, Gear: Park, Ignition: Off, no trip logged.

R v Boudreault 2012 SCC 56 — care or control requires a realistic risk of danger. Engine off. No keys. Not owner. No movement. Three witnesses confirm.

Tesla Audio — 14:41:06 EDT — 1 Minute Before Arrest

"I'm unable to operate or drive this car. There is no keys and I don't have access to the key. I'm also not the owner."

Clear, unambiguous exculpatory statement on camera and audio — directly addressing every element of the care or control charge.

Made one minute and one second before the arrest was announced. On the record. Cannot be disputed.

Crown's own complainant confirmed: vehicle not moving, no operation observed. Three signed witness statements corroborate.

Tesla Audio — 14:27:44 EDT — s.10(b) Invocation

"I'm not doing or saying anything without a lawyer present."

Right to counsel invoked at 14:27:44 EDT. Officer continued demanding ID 11 seconds later. R v Manninen — all demands must cease immediately.

Kruse Law named in Interview Room 9. Three named requests made during custody. Zero responses.

Police called duty counsel twice (16:46 and 17:19). Zero calls to Kruse Law. Steffler made SIX calls to Monica Cosby (vehicle owner, 72 years old) — zero to named counsel.

First police contact with Kruse Law: 07:48 AM March 16 — by an unidentified next-shift officer.

Total s.10(b) denial: 17 hours and 20 minutes. Kruse Law confirmed in writing: zero police contact on March 15 or 16 from arresting officers.

5 badge demands made on camera. Demand #1: 14:32:10 — no response. Demand #2: 14:33:17 — no response. Demand #3: 14:34:21 — Officer: "You don't need my badge number. I don't need my badge number." Explicit refusal. Demands #4 and #5 finally produced Badge WA1730 (Steffler). CSPA 2019 — 5 independent violations.

Tesla Security Recording — 14:42:02 EDT

CEW pressed to shoulder. Three-officer extraction. Booking report: "Force used: No."

At 14:42:02, a CEW (taser) was pressed to the accused's shoulder. At 14:42:05:

"You're going to tase me for sleeping in my car in front of my house?" — Accused
"YES." — Officer

Cst. Steffler (Tesla interior cabin T+15:40): gripping accused's forearm and clothing, physically pulling him from vehicle, smiling. Booking report: "Force used: No. Conductive Weapon used: No." Both false. Steffler authored her own cover-up.

Ontario Reg. 926/90 — mandatory Use of Force Report when CEW drawn. Never filed. Never disclosed.

Breath Session 1 — 16:28:45 EDT — Accused Never Enters the Room

Left: ceiling camera D181. Right: wall camera D180. Duration: 2 minutes 36 seconds. s.10(b) breach at this moment: 2 hours, 1 minute, 1 second.

The accused was on the designated accused's bench in the hallway outside the breath room door for the entire session. Cst. Steffler stood in the doorframe watching him. The accused's chair inside the room was empty throughout.

Session 2 (17:35:11 EDT): Accused in breath room but placed on bench beside Intoxilyzer, never in accused's chair. Eyes closed approximately 7 of 9.3 minutes. Demand read to incapacitated accused. Officers smiling at 17:39:25 and 17:41:25. s.10(b) breach: 3 hours, 7 minutes, 27 seconds.

R v Bernshaw [1995] 1 SCR 254 — a refusal must be clear and unequivocal, with a reasonable opportunity to comply. Neither session meets this standard. Count 2 has no foundation.

The False Document Chain — R v Nixon 2011 SCC 34

Four officers and Crown counsel. One false record. Endorsed four times.

Steffler WA1730

Crown Synopsis

"X1 conviction Impaired, X1 Refusal (Feb 2026)"

Steffler WA1730

Show Cause — Bail

Same false record to bail justice

A. Dueck, Crown

ACSF Scope 2028158

Increased penalty checked. Custody checked.

Smith-Morton 1723

s.727 Notice

Prior convictions. Served day of arrest.

CPIC — Same Crown Package

NO HIT

Zero prior convictions. The CPIC printout and all four false instruments are in the same Crown disclosure package. Self-contained contradiction.

Intoxilyzer 9000 — SN 90-004868

000

mg/100mL. Zero blood alcohol. Crown's own instrument at 15:44:42 EDT. Count 1 over-80mg has zero evidentiary foundation in Crown's own disclosure.

R v Nixon 2011 SCC 34

Stay Warranted

Crown counsel (Dueck) endorsed Steffler's false record in the ACSF. Crown participated in the false instrument. This is abuse of process at the prosecutorial level.

Resolution Position

Five independent grounds for full withdrawal — any one warrants a stay

Ground 1

No Valid Demand — Zero BAC

Intoxilyzer: 000 mg/100mL. Eyes closed during demand. R v Bernshaw. No valid demand = no valid refusal. Count 1 and Count 2 collapse on Crown's own evidence.

Ground 2

s.10(b) Total Denial — 17h20m

Invoked 14:27:44. Never discharged. 3 named requests — zero responses. Duty counsel redirect without attempting named counsel. Bail under breach. Manninen + Willier + Bartle.

Ground 3

False Sworn Statements — Crown Endorsed

4 false instruments. Crown endorsed. CPIC: NO HIT. R v Nixon 2011 SCC 34 — abuse of process. Stay warranted.

Ground 4

No Operation — R v Boudreault

Laptop on wheel. Engine off. No keys. Not owner. 3 witnesses + Crown's own complainant. Tesla telemetry: 0 km/h. R v Boudreault 2012 SCC 56 — no realistic risk of danger.

Ground 5

Tesla Telemetry + 9-Camera Recording — Irrefutable

6 independent data points confirm vehicle never moved. 9-camera system documents entire arrest for 19 minutes and 17 seconds. This evidence cannot be challenged or explained away.

June 23, 2026 — Appearance Strategy

Four objectives. One appearance.

"Your Honour, I am self-represented. I have Charter applications I intend to bring. The Trial Coordinator has confirmed that a self-represented judicial pretrial is required before Charter hearing dates can be scheduled. I am requesting that the court schedule a judicial pretrial at the earliest opportunity."

Request Judicial Pre-Trial

Required before Charter dates can be scheduled. Confirmed by Trial Coordinator Esther Turner (esther.turner@ontario.ca).

Learn the H-P Crown's Name

File managed by H-P surname Crown. Jane Young takes no direct contact. Get name on record.

WRPS Disclosure Update

Crown was waiting on police disclosure at May CPT. Ask if received. Re-offer Tesla footage. Quiet resolution still open.

Bail Variation — Condition 4

"No front seat" — agreed under s.10(b) breach without counsel. R v Bartle. Disproportionate.