Ten complaints to the Law Society of Ontario over ten years. Every one dismissed as “frivolous” within two to four weeks. Not a single one reviewed the audio recording in which the lawyer admits — in his own voice — to forging bank statements. Approximately CAD $400,000 was stolen from the Estate of Ivan Valentich. A 328-page investigation binder documents every signature, every transaction, every party. This page is the public evidence record.
David Simetic joins Francesco Giovanni Longo and the Estate of Raffi Ceylan as the third principal plaintiff of the Windsor Justice Trifecta. The Groot family — Norman Groot, 1999 Peel Regional Police obstruction-of-justice conviction, and Dr. Emily Groot, Ontario Chief Coroner during the 2016 Raffi Ceylan investigation — is the cross-chapter bridge that unites his claim with the Ceylan claim under s. 467.1 of the Criminal Code (criminal organization).
An audio recording in David Simetic's possession captures the Defendant Jerry L. Goldberg admitting to forging bank statements in connection with the Estate of Ivan Valentich. Chain of custody documented in the 328-page binder. Never heard by the Law Society in ten years of complaints.
Norman Groot, then a serving Peel Regional Police officer, was convicted in 1999 of obstruction of justice and fabrication of evidence. This conviction is the legal fact that establishes the Groot-family pattern of obstruction at the heart of the cross-chapter bridge.
Search CanLII →Every complaint dismissed as “frivolous” within two to four weeks. No audio reviewed. No forged document examined. No witness interviewed. Foundation of the Track B Judicial Review component and of the Charter s. 7 argument that unreviewed dismissal of proven misconduct is unconstitutional.
CAD $132,000,000 recommended floor (Exhibit 17-SIMETIC Damages Multiplier Schedule, 27 April 2026). This replaces the provisional CAD $60M figure from the Three-Track Litigation Plan, which was flagged "TBD · awaiting calculation." The new number applies the same per-perpetrator × years × crimes methodology used for the Ceylan chapter — 20 years of estate fraud, 4 individual perpetrators (Goldberg, Fullerton, Norman Groot, Emily Groot), 5 institutional defendants (LSO, Shibley Righton, Peel Regional Police, Office of the Chief Coroner, Ontario SCJ/LECA), Whiten punitives, Ward Charter damages, aggravated damages for 10×10 LSO dismissal pattern, plus RICO enhancement. This is a floor, not a cap — final judgment may exceed it.
→ Read Exhibit 17-SIMETIC · full damages calculation (PDF)
Unified Trifecta recommended floor: CAD $642,000,000+ across all three chapters, subject to upward revision at trial.
The following core materials are already on the record; they will be tendered as exhibits at appropriate stages of proceedings:
| Artifact | Location |
|---|---|
| Dave Simetic · Chapter 3 case page | genspark_mirror/nxffhryi.gensparkspace.com/dave-simetic.html |
| Chapter 3 skeleton (cross-references and FOI status) | genspark_mirror/nxffhryi.gensparkspace.com/dave-simetic-chapter.html |
| Three-Track Litigation Plan (20 Jan 2026) | genspark_mirror/.../DAVE_SIMETIC_THREE_TRACK_LITIGATION_PLAN.html |
| FOI request package | genspark_mirror/.../DAVE_SIMETIC_FOI_REQUEST_PACKAGE.md |
| Statement of Claim viewer ($60M SOC) | genspark_mirror/.../dave-simetic-motion-viewer.html |
| 328-page investigation binder | To be tendered under Rule 30.02, Rules of Civil Procedure |
| Defendant | Year | Matter | Link |
|---|---|---|---|
| Norman Groot | 1999 | Peel Regional Police · obstruction-of-justice CONVICTION · R. v. Groot | Simetic chapter (this page) |
| Dr. Emily Groot | 2016 | Ontario Chief Coroner · Raffi Ceylan death investigation · no strychnine test · 3 recorded calls with Lucy Ceylan | Ceylan chapter (/raffi) |
The family relationship between the two Defendants, combined with the documented misconduct by each in institutional roles twenty-seven years apart, is the foundation for the joint-enterprise criminal organization claim pleaded under s. 467.1 of the Criminal Code, R.S.C. 1985, c. C-46, against all 24 Defendants jointly and severally.