Motion For Evidence From Respodent

Evidentiary Petitions Evidentiary Petitions Denied 1. Request for invitation of Bulgarian Helsinki Committee as an interested 3rd party. Discovery Requests Unsatisfied 2. Respondent unable to produce copy of original letter authored by Deputy Minister for Justice Dimitar Bangalov and forwarded, via the Embassy for the Republic of Bulgaria to Canada in November 2005 addressed to the wife of the Applicant Tracy Coburn Kapoustin and advising her that according to Bulgarian national law as a foreign citizen I was not eligible for parole. 3. Applicants Exhibit No. 1 - Page 7 of the “Information Brochure on the Rights and Obligations of Prisoners in the Sofia Prison Elaborated with the Financial Support of the European Initiative for Democracy and Human Rights Sofia 2003” and where it writes “conditional early release [parole] will not be apply for those [nonBulgarian citizens] who have unpaid debts”. Court requested from Respondent the Bulgarian text and author of the Order having made an addendum to Art. 70(1) of the Bulgarian Criminal Code establishing a financial and nationality criterion as an element sine qua non for a non-Bulgarian citizen to candidate for parole. 4. 5. New Discovery requests - from Respondent; 1. Produce copy letter No. 3774/13.05.2005 issued by the “Ministry for Justice International Legal Assistance” – to Gov. Canada? 2. Document “справка’ to SCC showing that my working days were reported to the court for art. 70 CC hearing on 27.04.2006?