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

R v Le Blanc

Ontario Court of Justice, Kitchener  |  Information 4411-998-26-44101707-00
38
Charter Breaches
000
BAC mg/100mL
0 km/h
Vehicle Speed
17h20m
s.10(b) Denial
4
False Documents
9
Camera Angles
Tesla Security Recording — March 15, 2026 — 9 Cameras

The Scene — Engine off. No keys. Laptop on 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 state: Engine off. Gear: Park. Speed: 0 km/h. Accused was not the owner and had no access to keys.

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

R v Boudreault 2012 SCC 56 — no realistic risk of danger. This test is not met on these facts.
Crown's own complainant: "Vehicle not moving. No operation observed."
Tesla Audio — 14:41:06 EDT

"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."

This statement was made on camera and audio at 14:41:06 EDT — one minute and one second before the arrest was announced.

It is a clear, unambiguous exculpatory statement that directly addresses every element of the care or control charge.

Engine off. No keys. Not owner. Stationary. R v Boudreault — Count 1 and Count 3 cannot survive this on this record.
Tesla Audio — 14:27:44 EDT — s.10(b) Invocation

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

The right to counsel was invoked at 14:27:44 EDT. The officer continued demanding ID 11 seconds later.

R v Manninen — all questioning and demands must cease immediately upon invocation. The officer's continued demands are a breach from the first second.

Kruse Law was named during Interview Room 9 questioning. Three separate named requests were made during custody. Zero responses to any of them.

First police contact with Kruse Law: 07:48 AM March 16 — 17 hours and 20 minutes later.

Total s.10(b) denial: 17 hours and 20 minutes. Kruse Law confirmed in writing: no police contact on March 15 or 16 from arresting officers.
Tesla Security Recording — 14:42:02 EDT

CEW pressed to shoulder. "YES" — officer confirmed she would deploy it.

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?"
"YES."

Cst. Steffler's arrest booking report: "Conductive Weapon used: No."

Physical extraction by three officers follows at ~14:42:30. Booking report: "Force used: No."

Both entries are false. The Tesla recording documents what the booking report denies. Steffler authored her own cover-up. Ontario Reg. 926/90 — mandatory Use of Force Report never filed.

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

Left: ceiling camera D181. Right: wall camera D180. Duration: 2 minutes 36 seconds.

The accused was on the designated bench in the hallway outside the breath room door for the entire session. Cst. Steffler stood in the doorframe. The accused's chair inside the room was empty throughout. s.10(b) breach at this moment: 2 hours, 1 minute, 1 second.

R v Bernshaw [1995] 1 SCR 254 — a refusal must be clear and unequivocal. The accused was never in the room. No valid demand was made. No voluntary refusal occurred. 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 Result in Same Package
NO HIT

Zero prior convictions. The CPIC printout and the false-record documents are in the same Crown disclosure package. The contradiction is self-contained within Crown's own materials.

Intoxilyzer 9000 — SN 90-004868
000

mg/100mL. Zero blood alcohol. Crown's own instrument. Subject Test 15:44:42 EDT. Count 1 (over-80mg) has no evidentiary foundation anywhere in disclosure.

R v Nixon 2011 SCC 34

Stay Warranted

Crown counsel (Dueck) endorsed Steffler's false record in the ACSF. The Crown is not a passive recipient — Crown participated in the false instrument. Abuse of process.

Resolution Position — Full Withdrawal All Three Counts

Five independent grounds. Any one warrants a stay.

Ground 1

No Valid Demand — Zero BAC

Intoxilyzer: 000 mg/100mL. Eyes closed during demand, instrument not presented. R v Bernshaw — no valid demand, no valid refusal. Count 1 and Count 2 collapse.

Ground 2

s.10(b) Total Denial — 17h20m

Invoked 14:27:44. Never discharged. 3 named requests — zero responses. Duty counsel redirect. Bail under breach. Manninen + Willier + Bartle.

Ground 3

False Sworn Statements — Crown Endorsed

4 officers + Crown counsel each placed false prior convictions in the record. CPIC: NO HIT. R v Nixon 2011 SCC 34 — abuse of process — stay warranted.

Ground 4

No Operation — Boudreault

Laptop on wheel. Engine off. No keys. Not owner. 3 witnesses + Crown's complainant. Tesla: 0 km/h. R v Boudreault 2012 SCC 56.

Ground 5

Tesla Telemetry — 6 independent data points — Vehicle never moved — 9 camera system — entire incident on film

GPS stationary. 0 km/h. Odometer unchanged. Gear: Park. Ignition: Off. No trip logged. This evidence is not challengeable. The arrest is documented from 9 angles for 19 minutes and 17 seconds.

June 23, 2026

Four objectives. One appearance.

"Your Honour, I am self-represented. I have Charter applications I intend to bring. The Trial Coordinator has confirmed a 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."
1

Request Judicial Pre-Trial

Required before Charter hearing dates can be scheduled. Confirmed by Trial Coordinator Esther Turner.

2

Learn the H-P Crown's Name

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

3

WRPS Disclosure Update

Crown was waiting on police disclosure at May CPT. Ask if received. Re-offer Tesla footage for quiet resolution.

4

Bail Variation — Condition 4

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