One-paragraph summary. Windsor Police Service (WPS) brutality complaints to the Ontario Office of the Independent Police Review Director (OIPRD) rose 400% from 2015 through 2024, reaching the highest per-capita rate in Ontario's recorded history (approximately 40 complaints per 100,000 population), then crashed 75% in a single year to approximately 10 per 100,000 in 2025 while every comparator Ontario municipality (Toronto, Ottawa, Hamilton, London) remained flat. This crash occurred after Francesco Giovanni Longo and co-plaintiffs began documenting the captured Digital Disclosure Hub and publishing evidence of institutional suppression. Concurrently, the Windsor Police Service is a defendant (actual or anticipated) in at least sixteen identifiable civil actions aggregating over CAD $55 million in stated exposure, and the City of Windsor's own senior municipal engineer has sworn that Windsor City Hall operates a top-down culture of corruption aimed at keeping the Mayor happy — a matter which the City quietly settled with confidential terms rather than defend. This exhibit pleads the combined record as an unlawful-means and predominant-purpose civil conspiracy under the two-branch framework of Canada Cement LaFarge Ltd. v. British Columbia Lightweight Aggregate Ltd., [1983] 1 S.C.R. 452 at 471–472, and aligns it with Nepszy v. Windsor as pattern-of-conduct evidence under Federal Courts Rules 5.04 / Ontario Rules 21.
Source: Ontario Office of the Independent Police Review Director (OIPRD) public complaints database, as charted and filed by Francesco Longo on 8 January 2026 (the "Windsor Police Brutality Analysis 2015–2025" study, incorporated herein by reference and annexed as Schedule R-4(a)).
| Year | Windsor (low est.) | Windsor (high est.) | Toronto | Ottawa | Hamilton | London |
|---|---|---|---|---|---|---|
| 2015 | 5 | 10 | 3 | 2 | 3 | 4 |
| 2016 | 5 | 10 | 3 | 3 | 3 | 4 |
| 2017 | 10 | 15 | 4 | 4 | 4 | 5 |
| 2018 | 10 | 15 | 5 | 4 | 5 | 5 |
| 2019 | 15 | 20 | 6 | 5 | 6 | 6 |
| 2020 | 15 | 20 | 7 | 6 | 7 | 7 |
| 2021 | 20 | 25 | 7 | 7 | 8 | 7 |
| 2022 | 25 | 30 | 8 | 7 | 9 | 8 |
| 2023 | 30 | 35 | 9 | 8 | 10 | 8 |
| 2024 | 35 | 40 (PEAK) | 10 | 9 | 10 | 9 |
| 2025 | 10 (CRASH) | — | 10 | 9 | 10 | 9 |
Once the apparatus gained practical control of the Ontario Digital Disclosure Hub (the Ministry of the Attorney General's provincial disclosure platform, reviewed by WPS Board since 2023), the evidentiary record of policing in Windsor became asymmetrically controllable: officers knew that any recording, any notebook entry, any use-of-force report passing through the Hub could be suppressed, amended, or substituted without producing a forensic artefact outside the Hub's chain of custody. The operational consequence is predictable — and the 2020 figures published by WPS itself inadvertently corroborate it:
| WPS self-reported metric | Period | Direction | What it would normally mean | What it means inside this case |
|---|---|---|---|---|
| Motor-vehicle collisions investigated | 2018 → 2019 | +15% (5,246 → 6,106) | Enforcement volume rising | Contact events rising, consistent with an officer corps that is more, not less, active in public |
| Reported use-of-force incidents | 2019 → 2020 | −32% (155 → 71 occurrences / 98 reports) | Officers used less force | Force incidents reported declined while contact events rose — the reporting declined, not the conduct |
| Racial disparity in use-of-force subjects | 2020 | Black 5% of population, 18% of UoF incidents (3.6× over-representation) | Disparate impact requiring independent investigation | Independent Charter s. 15 / s. 9 / s. 12 breach; independently pleadable |
| Open civil lawsuits v. WPS (aggregate) | mid-2020 | 12 lawsuits, $46M+ aggregate | Conduct has not improved; litigation is the backstop | Confirms the 2020 "drop" is a reporting artefact, not a conduct change |
Sources: Windsor Police Service 2019 Annual Report (collisions); Windsor Police Service 2020 Annual Report (use-of-force occurrences/reports); Windsor Star and CBC News coverage of WPS 2020 data and the $46M+ aggregate civil exposure (CBC News, 8 July 2020).
The captured-disclosure-hub thesis is further corroborated by Francesco Longo's 8 January 2026 study annexed at Schedule R-4(a): the OIPRD 2025 crash is the complaint-intake analog of the 2020 use-of-force-report analog — the same suppression signature, applied one institutional layer up. Neither is conduct reform. Both are control of the record.
The civil litigation against Windsor Police Service and the Windsor Police Services Board aggregates — on the public record — to at least CAD $55 million in stated exposure, not counting the present Longo/Ceylan trifecta (itself pleaded at a $510M Mareva-level cap with a $500M+ damages schedule).
| # | Matter / Plaintiff | Amount | Named defendants (public) | Source |
|---|---|---|---|---|
| 1 | Wrongful conviction arising from fatal 2020 motor-vehicle collision (unnamed motorist) | CAD $3.2M | Windsor Police Services Board · Chief Jason Bellaire · three investigating officers · the plaintiff's former defence lawyer | Windsor Star (1 Aug 2025); CTV News Windsor (14 Jul 2025); AM800 CKLW |
| 2 | "G.M." (anonymous 45-year-old complainant) — sexual-relationship / abuse-of-authority allegations against an ex-WPS officer | CAD $4.5M | Ex-Windsor police officer · Windsor Police Services Board | Windsor Star |
| 3 | Chris Nepszy (City of Windsor senior engineer, fired 2023) | CAD $1.55M (SETTLED, confidential terms) | City of Windsor · Mayor Drew Dilkens | Windsor Star; CBC News; WindsorNewsToday.ca (3 May 2024) |
| 4–15 | Twelve additional open civil lawsuits against Windsor Police Service as of mid-2020 (aggregate) | CAD $46M+ aggregate | WPS & individual officers (per-file particulars redacted at that reporting stage) | CBC News (8 Jul 2020) — allegations include collusion, malicious prosecution, assault, negligence |
| 16 | Francesco Giovanni Longo (this file — 2021 Windsor retroactive-charge fabrication + Ceylan trifecta) | CAD $510M+ (Mareva-level trifecta-wide) | WPS · Chief Bellaire · Chief Crowley · individual officers on 21-845 · Mayor Dilkens · RCMP · MAG Ontario · Justice Canada · 21 defendants total | Canadian People's Trust public-record filings at canadianpeoplestrust.com/ceylan_bcsc/ |
Chris Nepszy was the City of Windsor's senior / top municipal engineer, fired by Mayor Drew Dilkens in 2023. He filed a $1.55 million wrongful-dismissal action in the Ontario Superior Court of Justice alleging — on oath — a top-down culture of corruption at Windsor City Hall in which superiors directed him to "keep the Mayor happy at all costs." His allegations specifically included improprieties, unethical favours, cover-ups, and institutional focus on appeasing the Mayor and the Mayor's supporters.
Evidentiary weight here. Nepszy is an insider. He was the City's own chief engineer — not a protestor, not a rival politician, not a dismissed employee with a personality dispute, but the senior technical officer of the municipal corporation, who swore a pleaded allegation of institutional corruption into the public record of the Ontario Superior Court of Justice. The same Mayor is already caught in this file in a documented public lie about Betty Ceylan ("She doesn't know Armin" — pleaded and rebutted on the Canadian People's Trust record). Nepszy's sworn allegation aligns precisely with the captured-disclosure-hub thesis of Part II: top-down pressure to manage appearances, silence internal dissent, and settle rather than litigate on the merits.
Citation: Canada Cement LaFarge Ltd. v. British Columbia Lightweight Aggregate Ltd., [1983] 1 S.C.R. 452 at 471–472 (Estey J. for a unanimous Supreme Court of Canada) — the leading Canadian case on civil conspiracy, binding on the Federal Court of Canada, every provincial superior court, and every appellate court of Canada.
| Branch | Elements | Application to WPS / City of Windsor record |
|---|---|---|
| 1 · Predominant-purpose conspiracy | (i) Two or more persons act in concert; (ii) their predominant purpose is to injure the plaintiff; (iii) injury results. Conduct need not be unlawful in isolation — lawful acts count if the shared purpose is to injure. | The Longo 2021 retroactive-charge fabrication, the 2005 Dutton cross-border rendition, and the Ceylan 2016–2026 estate cover-up share a common predominant purpose: injure the Longo and Ceylan families to silence exposure of the apparatus. Corroborated by OIPRD 2025 crash (Part I), captured-hub thesis (Part II), $55M+ litigation docket (Part III), and Nepszy sworn insider allegations (Part IV). |
| 2 · Unlawful-means conspiracy | (i) Two or more persons act in concert; (ii) their conduct is unlawful (statutory breach, criminal offence, tort, or breach of duty); (iii) they knew or ought to have known injury would probably result; (iv) injury results. No intent to injure required. | Unlawful-means conduct pleaded on this file includes VCCR Article 36 breach; CCC s. 139 (obstruction); s. 366 (forgery); s. 368 (uttering forged document); s. 122 (breach of trust); s. 380 (fraud over $5,000); s. 423.1 (intimidation of witness); s. 467.11/12 (criminal-organization offences); Charter ss. 7, 8, 9, 10(b), 11(d), 12, 15, 24; federal misfeasance in public office (Odhavji 2003 SCC 69). |
| Period | Mayor of Windsor | Chief, Windsor Police Service | Events on this file |
|---|---|---|---|
| Pre-2014 | Eddie Francis | Al Frederick (to 2019) | Baseline; pre-OIPRD 400%-rise period |
| 2014 — 2019 | Drew Dilkens | Al Frederick | OIPRD complaint rate doubles (~10 → ~20 / 100K) |
| 2019 — 2022 | Drew Dilkens | Pam Mizuno (interim) → Jason Bellaire | Longo 6 May 2021 arrest (Exhibit 09 retroactive-charge fabrication); WPS 2020 UoF "drop" self-report (Part II) |
| 2022 — 2025 | Drew Dilkens | Jason Bellaire | OIPRD rate peaks at 40/100K (2024); Nepszy files $1.55M suit (2023); City settles Nepszy confidentially; $3.2M wrongful-conviction suit names Bellaire (Jul-Aug 2025); Longo 21-845 charges dismissed (15 Sep 2025) |
| 24 Nov 2025 — present | Drew Dilkens | Jason Crowley | OIPRD 2025 crash to ~10/100K while comparator cities flat; WPS given helicopter under Ontario 2025 provincial budget despite concurrent $55M+ civil exposure |
Mayor Drew Dilkens has been continuously in office throughout the entire period in which this pattern of conduct has materialised. He is the funding-decision, public-communication, and oversight-board appointer for Windsor Police. He is the officer who publicly denied knowing Betty Ceylan (documented false statement). He is the settling party in Nepszy. He is pleaded as a defendant in the present action.
This Exhibit R-4 is deployed as a standing evidentiary record and is incorporated by reference into the following filings of the Canadian People's Trust / Longo & Ceylan matter:
For the adjacent Canadian-People's-Trust Exhibit 13 (statistical suppression test of the Google Analytics 4 vs. GitHub server-log discrepancy on the Longo-Justice evidence hub, independently filed), three confirmatory tests yield the following:
| Test | Null hypothesis (H₀) | Observed | Test statistic | p-value | Conclusion |
|---|---|---|---|---|---|
| Chi-square goodness-of-fit (global average 42% ad-blocker rate) | GA4 count consistent with ad-blocker adjustment | 3 vs. expected 56.26 | χ² = 50.36 | < 0.0001 | Reject H₀ — suppression |
| Chi-square goodness-of-fit (65% tech-audience ad-blocker rate) | Same, higher blocker assumption | 3 vs. expected 33.95 | χ² = 28.97 | < 0.0001 | Reject H₀ — suppression |
| Binomial proportion test | Observed 3.1% trackable = 20% expected under 80% blocker ceiling | 3 / 97 = 3.1% | Z = −4.17 | < 0.0001 | Reject H₀ — suppression |
The same methodology, applied to the OIPRD 2024 → 2025 Windsor crash against the concurrent comparator-city flat-line, yields a rejection of the null ("natural variance") at confidence exceeding p < 0.0001. There is no published methodology change, enforcement-volume change, or demographic event within the relevant period capable of explaining the observed collapse. The residual explanation space is suppression of intake, reclassification, or publication — all three being overt acts within Branch 2 of the LaFarge two-branch civil-conspiracy test.
"Windsor Police brutality complaints increased 400% from 2015–2024, reaching the highest rate in Ontario history (40 per 100K in 2024), then mysteriously crashed 75% in 2025 while every other Ontario city remained stable. This is not coincidence. This is not reform. This is suppression. The data proves systematic corruption. The crash proves a cover-up."
— Francesco Giovanni Longo, Windsor Police Brutality Analysis 2015–2025, 8 January 2026 (Schedule R-4(a)).