2022 QCCQ 13231, 2022 QCCQ 13231

Nature de la cause : Délaissement forcé Montant : Greffière : Yasmine D’Meza Interprète Sténographe Trivium Avocats inc. c. Ciarallo 2022 QCCQ 13231 CANADA PROCÈS-VERBAL D'INSTRUCTION AU FOND COUR DU QUÉBEC PROVINCE DE QUÉBEC Chambre civile DISTRICT DE MONTRÉAL Référée de Salle prévue 14.01 Date : 30 septembre 2022 No : 500-22-268298-216 L'HONORABLE ENRICO FORLINI, J.C.Q. JF1182

Partie demanderesse Avocat(s) 00 TRIVIUM AVOCATS INC. Présente Me Émilie Paquin Trivium Avocats Inc. epaquin@groupetrivium.com Présente

Partie défenderesse D Avocat(s) 00 MARK ANTHONY CIARALLO Présent Non représenté ENREGISTREMENT NUMÉRIQUE Audition AM : Début : 9 h 20 10 h 16 11 h 19 11 h 54 Fin : 10 h 09 10 h 26 11 h 47 12 h 14 Audition PM : Début : Fin : Résultat de l’audience : SUSPENSION DE L’INSTANCE 9 h 20 Ouverture de l'audience. 9 h 20 Identification des parties : Me Émilie Paquin, pour la

partie demanderesse; M. Mark Anthony Ciarallo, n’est pas représenté par avocat. Me Jean-François Gagné, représentant de Trivium avocats inc., est présent en visioconférence. 9 h 21 Le Tribunal résume le contenu des cinq courriels reçus hier de M. Ciarallo.

Demande de récusation 9 h 24 M. Ciarallo s’adresse au Tribunal. 9 h 30 Représentations de M.

Ciarallo. 10 h 09 Suspension. 10 h 16 Reprise. 10 h 16 Représentations de Me Paquin. 10 h 18 Réplique. 10 h 24 Le Tribunal ajourne l’audience jusqu’à 11 h 15 et rendra jugement à cette heure. 10 h 26 Suspension. 11 h 19 Reprise. 11 h 20 Judgment on application for recusation [ 1 ] The defendant, Mark Anthony Ciarallo asks for my recusation on the grounds of partiality. [ 2 ] This application comes on the heels of an application to postpone a two day trial scheduled for September 29 and 30, 2022, which the defendant served by email to opposing counsel, with a copy also being sent to the Court on September 28 at 10:27 PM. [ 3 ] The application to postpone was heard by the undersigned beginning at 9:30 AM on September 29.

After almost two hours of evidence and oral arguments, at 11:27 AM on September 29, I rendered oral reasons for judgment dismissing the application to postpone the trial. On the same day at 4:25 PM, the parties were sent the minutes of the hearing in which the oral reasons for judgment were transcribed. [ 4 ] Upon hearing the oral reasons for judgment, the defendant asked me to recuse myself.

He argued that given the reasons for judgment given on the application to postpone, he questioned my impartiality. [ 5 ] The Court requested that the defendant serve by email on opposing counsel, with a copy by email to the Court, a written application for recusation no later than 6:00 PM on September 29, 2022. [ 6 ] The application for recusation was served by email at 5:36 PM on September 29.

It comprises 47 paragraphs over 19 pages and includes one exhibit (minutes of a hearing before Justice Mark Shamie, June 16, 2021, in which he granted defendant’s application for postponement in another file of the Court of Québec – this exhibit had already being filed in support of the application to postpone). [ 7 ] At 5:58 PM, the defendant also submitted by email in support of his application for recusation 62 pages of written submissions. During oral arguments, he asked the Court not to consider this 62 page document seeing that he had sent a second written submissions later in the evening.

Indeed, in addition to the 62 pages written submissions, the defendant submitted an additional 31 pages of written submissions at 11:02 PM on September 29. [ 8 ] The defendant raises the following grounds for recusation of the undersigned in his application: 1. In the undersigned’s oral reasons for judgment rendered on the morning of September 29, 2022 dismissing his application for postponement, the undersigned stated that “he did not believe” two medical notes he had filed in support of the application to postpone, namely Dr. Prupas’s note and Dr.

Lafferiere’s note, insinuating that these two documents were “tampered”, were not authentic and thereby making a negative finding on the defendant’s credibility. These comments call into question the fairness of the future trial (see paragraphs 7 to 24 of the application for recusation). 2. The undersigned made certain “surprising and unusual statements in open court”; specifically the undersigned:

a) in welcoming the lawyers at the beginning of the hearing on September 29 referred to the fact that the defendant had previously appeared before the undersigned within the past year in another unrelated case; and

b) the undersigned “used his own experience” to describe the defendant’s conduct during that court appearance (see paragraph 28 to 34 of the application for recusation) and

c) referred to the defendant’s conduct as a “ modus operandi ” thereby disparaging him. 3. The undersigned was unfair toward the defendant because:

a) he constantly counted minutes pertaining to the length of the defendant’s oral submissions or the lengths of his absences during recesses and

b) only gave the defendant 5 hours to prepare and file his application for recusation (see paragraph 36 and 38 of the application for recusation). [ 9 ] The defendant did not address this third ground in his oral submissions. [ 10 ] The application for recusation contains numerous other allegations, for example in paragraphs 35, 37, and 39 to 47, which in the Court’s view do not state grounds of recusation.

Rather the allegations in these paragraphs pertain to reiterating the same arguments he raised in support of his motion to postpone or alleging arguments as to why the undersigned’s decision on his motion to postpone is unfounded in fact. [ 11 ] Accordingly, seeing that these allegations are not relevant to the application for recusation, the undersigned will not further

address in this judgment the allegations contained in paragraphs 35, 37, and 39 to 47. [12] Before addressing the merits of the arguments raised by the defendant in his application for recusation and in his oralsubmissions, I will summarize the law governing an application for recusation.

The law governing an application for recusation [13] The recusation of a judge is governed by articles 201 and following of the Code of Civil Procedure (“C.C.P.”) There is only onegrounds for filing an application for recusation: the party must have serious reasons to question the judge’s impartiality. [14] The duty of impartiality is a fundamental pillar of our justice system. [15] It is specifically provided for in

article 9 of the C.C.P. : 9. […] Judges must be impartial and, in their decisions, they must have regard to the best interests of justice. [16] Moreover,

section 5 of the Judicial Code of ethics states that “The judge should be, and be seen to be, impartial and objective.” [17] In Ste-Marie v. R.[1], the Court of Appeal writes: [89] L’impartialité d’un juge est définie comme étant « l’état d'esprit de l'arbitre désintéressé eu égard au résultat et susceptible d'êtrepersuadé par la preuve et les arguments soumis » : R. c. S. (R.D.), (CSC), [1997] 3 R.C.S. 484, paragr. 104.

Lajurisprudence rappelle qu’invoquer la partialité d’un juge est une allégation grave puisque les juges jouissent d’une forte présomptiond’impartialité et sont capables de faire abstraction d’éléments de preuve inadmissibles : Bande indienne de Wewaykum c. Canada, 2003CSC 45, [2003] 2 R.C.S. 259, paragr. 2 et 76; R. c. Teskey, 2007 CSC 25, [2007] 2 R.C.S. 267, paragr. 30.

Celui ou celle qui demande larécusation d’un ou une juge doit établir une réelle probabilité de partialité par une preuve convaincante ou une crainte raisonnable etobjective de partialité, c’est-à-dire une crainte que ressentirait une personne sensée, raisonnable et bien informée : Cojocaru c. BritishColumbia Women’s Hospital and Health Centre, 2013 CSC 30, [2013] 2 R.C.S. 357, paragr. 29. L’apparence de partialité a les mêmesconséquences que la partialité réelle et, dans les deux cas, la prétention doit être soulevée le plus tôt possible : R. c. Curragh inc., (CSC), [1997] 1 R.C.S. 537, paragr. 11; Belleville c.

R., 2018 QCCA 960, paragr. 102; Hébert c. R., 2014 QCCA 1441,paragr. 33. [18] The Supreme Court has repeatedly recognized that there is a strong presumption of impartiality and integrity on the part ofjudges and their judgments[2] and that this presumption can be displaced only in exceptional circumstances based on concrete and cogentevidence.[3] [19] In Droit de la famille - 1559[4], the Court of Appeal summarized the test to be applied on an application for recusation : Pour être cause de récusation, la crainte de partialité doit donc:

a) être raisonnable, en ce sens qu'il doit s'agir d'une crainte, à la fois, logique, c'est-à-dire qui s'infère de motifs sérieux, et objective,c'est-à-dire que partagerait la personne décrite à

b) ci-dessous, placée dans les mêmes circonstances; il ne peut être question d'une craintelégère, frivole ou isolée;

b) provenir d'une personne: 1o sensée, non tatillonne, qui n'est ni scrupuleuse, ni angoissée, ni naturellement inquiète, non plus que facilement portée au blâme; 2o bien informée, parce qu'ayant étudié la question, à la fois, à fond et d'une façon réaliste, c'est-à-dire dégagée de toute émotivité; lademande de récusation ne peut être impulsive ou encore, un moyen de choisir la personne devant présider les débats; et

c) reposer sur des motifs sérieux; dans l'analyse de ce critère, il faut être plus exigeant selon qu'il y aura ou non enregistrement des débatset existence d'un droit d'appel. [20] In

summary, to determine the merits of an application for recusation, a party need not prove the existence of the judge’s bias.This would set the bar too high. The party must nevertheless be able to establish a reasonable apprehension of bias by a reasonable, right-minded and informed person who could conclude that, in all likelihood, the judge will not decide fairly. [21] That means that the assessment of the reasonableness of the apprehended bias must be based on specific facts and not on ageneral impression, and it must take into account the context.

As the Court of Appeal noted in Tokar: «[…] le contexte a donc une placeessentielle dans l’analyse du problème de la partialité et de l’apparence de partialité du juge».[5] [22] Finally, the bar for establishing a reasonable apprehension of bias is high. The comments with respect to the medical notes and the alleged finding on the defendant’s credibility [23] In the instant case, Mr. Ciarallo bases his accusation of bias on the fact that in my reasons for judgement dismissing hisapplication for postponement of the trial, I commented on some of the evidence he adduced, specifically the sick notes of Dr.

Prupasdated September 28, 2022 and Dr. Gilles Lafferiere dated August 31, 2022. [24] In stating that the 2 notes were “tampered” and were not authentic, he argues I made a negative finding of his own credibility.This raises a reasonable apprehension of bias in that on credibility issues in the trial, I won’t have an open mind. This argument is at the

heart of his pretention – he reiterated this argument notably at paragraph 12 of his written submissions. [25] He also argues that by describing his conduct as vigorous in a prior court appearance before me, this also impugned hiscredibility which also raises an apprehension of bias on issues of credibility for the trial. [26] It is important to cite the passages of the transcribed reasons for judgement on the application to postpone in which the courtaddresses the two medical notes: [50] Mr. Ciarallo alleges that he suffers from bladder cancer and is being treated by an oncologist at St.

Mary’s Hospital inMontreal. [51] Yet, the “sick notes” he produces in support of his application to postpone are purportedly signed by general practitionersfrom a medical clinic in Cornwall, Ontario. [52] The Court considers it surprising that he hasn’t supported his application with an expert medical assessment from hisoncologist at St. Mary’s. [53] Moreover, the two sick notes do not even make any mention of his cancer diagnosis nor contain any mention that he is unableto attend the trial set for September 29 and 30. [54] I add that the sick note signed by Dr.

David Prupas is strangely written in the past tense and the typed portion makes nospecific mention of his medical condition nor does it make reference of his participation in court proceedings. The wording is curiouslyidentical to the wording of the sick note Mr. Ciarallo filed in the court record in Court of Appeal file number 500-09-029708-211 asreported in paragraph 10 and 11 of Justice Kalichman’s decision reported at 2021 QCCA 1634.

In addition, the physician writes that Mr.Ciarallo “was unable to work and/or attend school due to medical reasons…” The reference to attending school for a patient who is 63years old simply adds to the reasons why the Court affords little credibility to this document. [55] What is even more troubling is the addition of the handwritten sentence in the Dr. Prupas sick note inserted after the typedportion where it is stated “including going to court or any other professional duties.” It leaves the court with serious questions as to theauthenticity of the document. I add that Dr.

Prupas’ provider number issued by the College of Physicians and Surgeons of Ontario doesnot appear on the note as one would expect otherwise. [56] As for the second “sick note” filed in support of his application to postpone, it is dated August 31, 2022 and purportedlysigned by Dr. Gilles Laferriere, also a general practitioner in Cornwall, Ontario and working out of the same office as Dr. Prupas.

It ison his letterhead and the statement “Mark is unable to work for one month because of medical reasons” is added in handwritten letters.The form of this sick note also raises doubts in the Court’s opinion as to its authenticity. [57] Here too, there is no mention of Mr.

Ciarallo’s cancer condition nor does it make reference to a participation in courtproceedings on September 29-30. [27] The defendant argues that these comments give rise to a reasonable apprehension of bias by a reasonable, right-minded andinformed person who could conclude that, in all likelihood, the judge will not decide fairly. [28] Respectfully, I disagree.

The case law of the Court of Appeal indicates that a finding of credibility by the trial judge incircumstances such as the present ones does not lead to the conclusion that there is reasonable fear of bias regarding another aspect of thecase. [29] A very similar argument was raised by the appellants in Malobabic v. O'Connor[6], Justice Sansfaçon addressed this issue asfollows: [8] In Radio-Canada c.

Syndicat des radiocommunications de Radio-Canada (FNC-CSN) (2016 QCCA 1588), this Court pointedout that the mere fact that a judge hears a party once again in another case is not grounds for recusation and the fact that a judge hasruled on the credibility of a witness (or a party) does not lead to the conclusion that there is reasonable fear of bias regarding anotheraspect of the case. A witness may be believed regarding certain facts, but not others. In the present case, the trial is over and the judge’srole is to manage and adjudicate the disputes arising during its execution.

Moreover, in his judgment dated November 14, 2019, thejudge demonstrated that he had kept an open mind, since he allowed an application for recusation made by Brana Malobabic’s spouse,for the reasons he set out therein. [Underlining added] [30] This same rule was reiterated in Giroux v. R.[7]: [32] La Cour a déjà par ailleurs décidé que le fait de rendre une décision défavorable à l’égard d’un accusé au cours d’un procès nepermet pas en soi de conclure à la partialité du juge.

Un juge peut avoir à se prononcer sur la crédibilité d'un accusé au cours d'un procèslors d'un voir-dire sans devoir se récuser par la suite. C'est plutôt le comportement du juge qui doit être analysé pour déterminer s'il existeau dossier une crainte raisonnable de partialité : R. c. S. (R.D.), (CSC), [1997] 3 R.C.S. 484. [Reference omitted] [31] In the present case, the comments made with respect to the sick notes were in the course of adjudicating the application topostpone.

These findings of credibility and probative value made in paragraphs 54, 55 and 56 of the transcribed reasons for judgment ispart and parcel of the work of every judge when he/she has to reach a decision. It does not show or raise a reasonable apprehension of

bias on the part of a reasonable, right minded and informed person aware of the context of the matter that was being decided and the issues at stake. [ 32 ] This interlocutory application has been decided and the next phase is the trial on the merits. [ 33 ] I reiterate that I have an open mind with respect to the issues to be adjudicated on the merits. Whatever findings I made with respect to the admissibility and probative value of the two sick notes in the course of deciding the application to postpone will have no bearing on my ability to hear the trial in a fair, objective and impartial manner.

As the Court of Appeal has stated, a judge can be obliged to make a finding of credibility with respect to a party at one stage of a proceeding, but that does not lead to conclusion of reasonable fear of bias regarding another aspect of the case. [ 34 ] Likewise, the Court disagrees that referring to the Defendant’s conduct in a prior proceeding where he appeared before me raises a reasonable apprehension bias. [ 35 ] The issue I had to decide with respect to the application to postpone was whether the defendant provided convincing and compelling proof that owing to his medical condition, a condition which he alleges has been ongoing for the past 30 months , he could not attend court on September 29 and 30, 2022. [ 36 ] Hence, whether he in fact practiced law and attended court in the past 30 months is relevant.

This is what I stated at paragraphs 39 to 41 of the transcribed reasons for judgment on the application to postpone: [39] Mr. Ciarallo has known since January 18, 2022 that the trial in this matter was set for today September 29, 2022. Yet he now claims he is without an attorney and could not prepare because he has been undergoing cancer treatments over the past 32 to 36 months.

His debilitating condition over the past 36 months have been a period of “daily fear and pain” according to his September 26 email (at 21:20). [40] Yet, over the past two years, he has appeared before the Supreme Court, the Disciplinary Council of the Barreau du Québec and also the Court of Québec on numerous hearings, some lasting over 7 days, as the aforementioned cited cases show. I add that Mr. Ciarallo has appeared personally before me on a number of times, including on January 26 and February 9, 2022 in the matter Ciarallo v. Wendell D’Souza and Mavis Nichols (500-22-270700-225).

During these court appearance, he vigorously and forcefully made oral submissions and did not appear to be medically unfit to attend court. [41] As Justice Sheehan writes in Ciarallo v. Dyotte ( 2020 QCCS 3990 ) at paragraph 65, this contradiction greatly affects Mr. Ciarallo’s credibility. [ 37 ] To describe his conduct as vigorous is not pejorative – nor would any person think so. In fact, in C.N. v.

McKercher [8] , the Supreme Court of Canada described the role of a lawyer as follows: “the lawyer be an effective representative – that he serve as a zealous advocate for the interests of his client.’’ [ 38 ] Describing a lawyer as someone who must be zealous is not pejorative. Likewise, describing the conduct of a lawyer as vigorous is not pejorative. It can be seen as a quality, not a negative trait. [ 39 ] Thus, to describe the defendant as vigorous was both relevant to the issue and not pejorative.

Form the standpoint of a reasonable well informed person aware of all the context, this statement does not give rise to a reasonable apprehension of bias. The alleged surprising and unusual statements I made with respect to past appearances of the defendant before me [ 40 ] Courts must take judicial notice of the law in force in the province. This includes the case law of the courts of this province.

The defendant is aware of this rule and even relies on it when he argued that the undersigned must take judicial notice of Justice Mark Shamie’s judgement rendered on June 16 2021 as well as the evidence he considered. [ 41 ] If I am to take judicial notice of the case law and proceedings presided by other judges of the courts of this province, à fortiori I can take judicial notice of the proceedings I myself have presided, including those where the defendant was a party. [ 42 ] Moreover there is nothing inappropriate for a judge to consider the conduct of a lawyer or a litigant that has appeared before him among the factors which he takes into account in reaching a decision.

I note that Justice Martin Sheehan did so in his judgement of November 27, 2020 [9] and so did Justice Yergeau in his August 23, 2021 judgement. [10] [ 43 ] The fact that I took into account the defendant’s conduct which I personally witnessed in presiding hearings in case number 500- 22-270700-225, proceedings in which he appeared as a party in January and February 2022, is directly relevant to the issue I had to decide on the application for postponement since he was arguing that due to his illnesses, he has been unable to attend court hearings since at least February 2020. [ 44 ] Taking into account this evidence, which was one element of evidence I considered among many other elements of evidence I considered in reaching my decision on the application to postpone, was not an indication of bias.

A reasonable person being aware of all the circumstances would not consider this conduct as giving rise to a reasonable apprehension of bias. [ 45 ] The defendant also claims that my use of the expression “ modus operandi ” in my oral reasons for judgment on the application to postpone gives rise to a reasonable apprehension of bias. [ 46 ] Respectfully, I disagree. I never used this expression as my own but, as it appears from the transcribed reasons for judgment, cited passages in a decision rendered by Justice M. Sheehan in Ciarallo v. Dyotte [11] : [26] Mr.

Ciarallo sought to stay the disciplinary proceedings of the Barreau du Québec. In his judgment dismissing Mr. Ciarallo’s

application to stay, Justice Martin Sheehan describes as follows the complaint filed by the Barreau in file 06-20-03294 (see 2020 QCCS 3990 ): [22] In the course of its motion, the Syndic states that Plaintiff, through the use of a modus operandi , has so far been able to circumvent the different mechanisms that have been put in place by the legislator to safegard the protection of the public. [23] This modus operandi consists in part of: … 23.2. Sending massive amount of emails which are incomprehensible and repetitive.

These emails contain an abundance of irrelevant information and are sent to a great number of people to create confusion mobilize resources and hamper investigations; 23.3. Sending numerous successive emails similar in appearance but with minor changes to force the recipient to read them completely in order to discover subtle nuances between them; … 23.12.

Asking for postponements and filing numerous proceedings on the day of hearings; … [ 47 ] This excerpt shows that Justice Sheehan was himself summarizing the Syndic du Barreau’s position. [ 48 ] Given the context in which the expression modus operandi was used, this would not give rise to an apprehension of bias for a reasonable, well informed person. [ 49 ] Finally, the defendant also raises the fact that he was surprised that I was assigned to hear this case owing that he appeared before me in practice court in January and February 2022.

He stated during oral submissions: “I’m worried why you’re in the file a second time.” [ 50 ] This charge is meritless and unfounded. Judges are not at all responsible for how and what cases are assigned to them. In the Court of Québec, Civil Division, district of Montréal, cases are assigned by the Maître des rôles. Judges of the Court of Québec have no say in what cases are assigned to them. To insinuate that there is something improper because of the fact defendant appeared before me twice in the span of 9 months is baseless.

This would not give rise to an apprehension of bias from a reasonable well informed person knowing how cases are assigned to judges of the Court of Québec, Civil Division, district of Montréal. The alleged unfairness of the undersigned because of time constraints put on the defendant [ 51 ] I will be brief with respect to the allegation of unfairness. [ 52 ] Pursuant to

article 9 C.C.P. judges must ensure proper case management ( saine gestion des instances ). [ 53 ] This is a 2 day trial and the date of trial has been known to defendant since January 2022. It is 11:20 AM on day 2 and the trial has not started. [ 54 ] It was entirely appropriate for me to be mindful of time issues on September 29 knowing that I had to address an interlocutory application presented on the morning of the trial, when, had the rule in

article 28 of the Regulation of the Court of Québec been respected, the hearing and decision on the defendant’s motion to postpone would have been handed down before the trial and trial time would not have been lost as we have over the course of the last 1 1/2 days.

Conclusion [ 55 ] The defendant has not rebutted the strong presumption of impartiality [ 56 ] Based on the specific facts raised by the defendant and in light of all the circumstances of this case, the defendant has not established a reasonable apprehension of bias by a reasonable, right-minded and informed person who could conclude that, in all likelihood, I will not decide the case on the merits fairly. FOR THESE REASONS, THE COURT: DISMISSES the application for recusation. ____________________________ ENRICO FORLINI, J.C.Q. 11 h 47 Suspension. 11 h 54 Reprise.

11 h 54 Preuve en demande. 11 h 54 M. Ciarallo informe le Tribunal qu’il va porter les décisions sur la demande de remise et sur la demande de récusation en appel. Vu l’intention de M. Ciarallo de demander la permission d’appeler des deux décisions, le Tribunal souhaite fixer une conférence de gestion afin de faire le suivi du dossier. Il demande à M. Ciarallo dans quel délai il compte déposer ses demandes pour permission d’appeler au greffe de la Cour d’appel. 11 h 57 M. Ciarallo demande au Tribunal de faire des copies de la pièce I-4 (dossier médical d’environ 300 pages). 11 h 57 Le Tribunal informe M.

Ciarallo qu’il n’incombe pas aux tribunaux de faire des photocopies de pièces volumineuses. 11 h 59 Me Paquin informe le Tribunal qu’elle n’est pas disponible la semaine du 24 octobre 2022. 12 h 02 M.

Ciarallo informe le Tribunal qu’il déposera les demandes de permission d’appel à la Cour d’appel au courant de la semaine du 24 octobre, donc au plus tard le 28 octobre 2022. 12 h 06 Ordonnance de gestion Vu que le défendeur a informé le Tribunal qu’il entend demander à la Cour d’appel la permission d’en appeler du jugement rendu hier sur la demande de remise et du jugement rendu ce matin sur la demande de récusation; Vu que M.

Ciarallo a informé le Tribunal qu’il entend signifier et déposer au greffe de la Cour d’appel ses demandes pour permission d’appeler au plus tard le 28 octobre 2022; Afin d’assurer une saine gestion de l’instance (art. 9 C.p.c. ); LE TRIBUNAL : SUSPEND la présente instance jusqu’à jugement de la Cour d’appel sur les demandes pour permission d’appeler annoncées par le défendeur des jugements rendus sur la demande de remise et la demande de récusation; CONVOQUE les parties à une conférence de gestion le 8 novembre 2022 à 14 h en salle 2.02 pour faire un suivi quant à l’état du dossier devant la Cour d’appel.

Me Paquin participera à la conférence de gestion en visioconférence et M. Ciarallo participera en personne. ____________________________ ENRICO FORLINI, J.C.Q. 12 h 12 M. Ciarallo identifie devant le Tribunal les documents dont il aimerait faire copie de la pièce I-4 12 h 14 Fin de l’audience. _________________________ Yasmine D’Meza