On December 16, 2022, Chris Horlacher filed the Second Supplementary Motion Record and the Moving Party’s Supplementary Factum in the Ontario Superior Court of Justice as part of the ongoing lawsuit against the Attorney General of Canada and CSIS.

These filings were made in response to requests arising from the earlier default judgment and provide additional sworn evidence and legal argument in support of the Plaintiffs’ claims.

The Filings

Download the Second Supplementary Motion Record here:

On the same day, a Supplementary Factum was also filed, summarizing the evidence presented in the Motion and the relevant case law to support our claims.

Download the Supplementary Factum here:

Key Content

The Supplementary Motion Record and Factum include updated evidence and address the Court’s previous requests, notably:

• The Crowe Soberman valuation report, which provides a professional assessment of damages suffered by Equibit Group Ltd.
• Further particulars and supporting documentation regarding the quantum of damages claimed.

These materials form an important part of the evidentiary record as the case advances.

Context and Significance

Filing supplementary motion records and factums is a standard but critical part of civil litigation, especially in complex cases involving significant damages and institutional defendants. By submitting this material, the Plaintiffs continue to build a detailed, documented case while responding directly to the Court’s directions.

This filing demonstrates Equibit’s commitment to transparency and procedural compliance, even as the government side has, at times, been slow to respond.

The Broader Picture

Every document filed in this proceeding adds to the permanent public record. Despite procedural delays and institutional resistance, the Plaintiffs continue to advance the case methodically and transparently.

The comprehensive public archive at equibitlawsuit.com exists to ensure citizens can review the evidence for themselves.

The full Factum of Equibit Group — the complete evidentiary synthesis of the entire matter — continues to advance and will be released in due course.

The pursuit of accountability continues.