BETWEEN:

Court File No. CV-16-1857-SR

ONTARIO SUPERIOR COURT OF JUSTICE

SAMUEL RONIN also known as SAM RONIN

Plaintiff / lVIoving Party and

LEV RONIN, ELENA RONIN, STAS RONIN also known as STAN RONIN, DANA RONIN, JOHN DOE and JANE DOE

Defendants / Responding Parties

AFFIDAVIT OF SAMUEL RONIN also known as SAM RONIN

I, SAMUEL RONIN also known as SAM RONIN, of the Regional Municipality of

York, in the Province of Ontario, MAKE OATH AND SAY:

1) I am the Plaintiff in these proceedings, and as such, I have personal knowledge

of the matters to which I hereinafter depose, save where I have been advised of

the same, in which case I have specified the source of the information and in all

such cases I do verily believe to be true such matters of which I have been

advised.

Background:

2) The parties to this action are all family members of one another.

3) The Defendants, Lev Ronin ("Lev") and Elena Ronin ("Elena"), are spouses of

one another and are my biological parents.

4) The Defendant, Stas Ronin also known as Stan Ronin ("Stan"), is my brother.

5) The Defendant, Dana Ronin ("Dana"), is my sister.

6) I was born on June 4, 1997; and as such, I am adult. I turned 18 years old on

June 8,2015.

7) Prior to or around June 30, 2015, I resided with my parents, Lev and Elena, in

their home located in Richmond Hill, Ontario. We, as a family, resided in

Richmond Hill, Ontario from or around November 23, 2000 to June 30, 2015.

8) Most of my life was spent in Richmond Hill, Ontario. I attended schools and the

majority of his friends reside in Richmond Hill, Ontario.

9) On or around June 30, 2015, Lev and Elena sold their home in Richmond Hill,

Ontario and purchased and relocated the family to Holland Landing, Ontario.

The address of the property which Lev and Elena purchased is municipally

known as 8 Arkinstall Court, Holland Landing, Ontario (the "Property"). Attached

hereto and marked as Exhibit "A" is a true copy of the parcel register of the

Property. Attached hereto and marked as Exhibit "8" is a true copy of the

Transfer registered as Instrument No. YR2314752 on June 30, 2015.

10) I did not want to relocate to Holland Landing, Ontario, and as such, on or around

June 26, 2015 chose not to relocate with his family in Holland Landing, Ontario.

11) Lev and Elena did not, and have not, accepted my decision as an adult to

relocate and live separate and apart from them.

Websites:

12) Since my decision not to relocate and move with my family to Holland Landing,

Ontario, Lev, Elena, Dana and/or Stan have created , or instructed others to

create, a website with a webpage known as www.WeMissSam.org.

13) Lev, Elena, Dana and/or Stan have also created , or instructed others to create, a

website through the social media networking website FaceBook. The said

website has a web address of www.facebook.comlWeMissSam.

14) Lev, Elena, Dana and/or Stan have also created, or instructed others to create ,

an online petition. The said website has a web address of

https://www.change.org/p/canadian-government-and-the-Iegal-system-protect­

families-from-having-their-children-brainwashed-into-joining-a­

cult?recruiter=502710296&utm source=share petition&utm medium=copylink

15) The three (3) websites, being www.WeMissSam.org ,

www.facebook.comlWeMissSam and https://www.change.org/p/canadian-

government-and-the-Iegal-system-protect-families-from-having-their-children­

brainwashed-into-joining-a-

cult?recruiter=502710296&utm source=share petition&utm medium=copylink

(hereinafter collectively referred to as the "Websites"), have been created, either

directly or indirectly, by the Defendants.

16) The Websites seek information regarding my whereabouts . In fact, I have notified

the Defendants and advised that I am in fact safe and well.

17) I have also notified the police and advised that I am not considered "missing" and

I am safe and well as Lev and Elena have filed a Missing Persons Report.

18) The Websites are open to the public for viewing and are very embarrassing. The

Websites suggest that I have been lured by an individual within a "secret

society", known as the Freemasons.

19) I am a student attending a major post-secondary institution (the name of which I

do not want to reveal) and many of my school peers have now visited and seen

the Websites - which in turn has been very embarrassing and awkward .

20) The Websites have offensive and embarrassing comments.

www.WeMissSam.org:

21) Attached hereto and marked as Exhibit "C" is a true copy of a printout from the

main page of the website www.WeMissSam.org.

22) Attached hereto and marked as Exhibit "0" is a true copy of a printout from the

section titled "The Story" of the website www.WeMissSam.org.

23) The "The Story" page of the website www.WeMissSam.org states:

Their son, Sam, age 17, had recently been introduced to Mr. Vicky

8agwalla by a high school classmate, who had asked Sam to come

along on a visit with him. As he was afraid to be alone with Mr.

8agwalla, Mr. 8agwalla is 42 years old, and one of the top

Freemasons. Sam at first expressed doubts about Mr. 8agwalla 's

boasts and accomplishments, but was soon spending a lot of time

with him. Mr. 8agwalla called Sam repeatedly, spent school lunch

hours with him, picked him up after school, offered him use of his

car, bought him expensive gifts, gave him marijuana, arranged

weekend sleepovers, and generally cultivated the relationship,

making Sam feel "special".

24) This information is false. At no time did Vicky Bagwalla "give" me marijuana.

Furthermore, Mr. Bagwalla did not arrange sleepover. The sleepovers which

occurred were with Dennis Gorya.

25) Attached hereto and marked as Exhibit "E" is a true copy of a printout from the

section titled "Who is Who" of the website www.WeMissSam.org .

26) Attached hereto and marked as Exhibit "F" is a true copy of a printout from the

section titled "Sam Ronin" of the website www.WeMissSam.org.

27) Attached hereto and marked as Exhibit "G" is a true copy of a printout from the

section titled "Vicky 8agwalla" of the website www.WeMissSam.org.

28) Attached hereto and marked as Exhibit "H" is a true copy of a printout from the

section titled "Robert Potts" of the website www.WeMissSam.org.

29) Attached hereto and marked as Exhibit "I" is a true copy of a printout from the

section titled "Dennis Gorya" of the website www.WeMissSam.org.

30) Attached hereto and marked as Exhibit "J" is a true copy of a printout from the

section titled "David Frankland" of the website www.WeMissSam.org.

31) Attached hereto and marked as Exhibit "K" is a true copy of a printout from the

section titled "Letter to Sam" of the website www.WeMissSam.org.

32) Attached hereto and marked as Exhibit "L" is a true copy of a printout from the

tab titled "References" of the website www.WeMissSam.org.

33) Attached hereto and marked as Exhibit "M" is a true copy of a printout from the

tab titled "Donation" of the website www.WeMissSam.org.

34) Attached hereto and marked as Exhibit liN" is a true copy of a printout from the

tab titled "Petition" of the website www.WeMissSam.org.

35) Attached hereto and marked as Exhibit "0" is a true copy of a printout from the

tab titled "Contract Us" of the website www.WeMissSam.org.

www.facebook.comlWeMiss5am:

36) As aforementioned, the Defendants, either directly or indirectly, have created a

webpage on the social media networking website, FaceBook. Attached hereto

and marked as Exhibit "P" is a true copy of a printout from the FaceBook

website.

37) There is an online link on the said FaceBook page which will open an article on

www.yorkregion.com titled "Are York boys being groomed for online

exploitation?" Attached hereto and marked as Exhibit "Q" is a true copy of the

said articles titled "Are York boys being groomed for online exploitation?".

38) There is also an online link on the said FaceBook page which will open another

article on www.yorkregion.com titled "Heartbroken parents warn how son was

lured away" Attached hereto and marked as Exhibit "R" is a true copy of the

said articles titled "Heartbroken parents warn how son was lured away".

Online Petition:

39) As aforementioned, the Defendants, either directly or indirectly, have created a

webpage on the online petition website, Change.org. Attached hereto and

marked as Exhibit "5" is a true copy of a printout from the Change.org website.

40) The said online petition is titled "Protect families from having their children

brainwashed into joining a cult".

41) I have by no means joined a "cult". The Defendants have not accepted the fact

that I do not want to live with Lev and Elena and have construed the decisions

which I have made as an adult.

42) The online petition website has various links back to www.WeMissSam.org .

Incidents of Concern:

43) On or around June 26, 2015, I visited Lev and Elena's residence to remove my

belongings as I no longer wished to resides with them. The majority of my life

was spent in Richmond Hill , Ontario, and as such, I did not want to relocate my

life to Holland Landing, Ontario.

44) Upon attending, Lev had physically assaulted and attempted to physically

restrain me from removing my belongings from their residence.

45) In or around December 2015, I was at Legends Warehouse in Woodbridge,

Ontario attending a gathering with friends. To my surprise, the Defendants

attended unannounced and uninvited and attempted to forcefully take me into

their custody. I was fortunate to escape the Defendants' said attempt.

46) I am also receiving numerous unwanted communications from the Defendants.

47) The Defendants' behavior is causing a great deal of concern to me. Furthermore,

the Defendants' behavior is also embarrassing to me as many of his friends and

school peers are aware of the circumstances .

48) I was advised by Vicky 8agwalla and verily believe that on April 10, 2016 Stan

attended Mr. Bagwalla's house seeking my whereabouts. Mr. 8agwa/la advised

Stan that I was not at his home.

49) Shortly thereafter and also on April 10, 2016, Stan attended my condominium

residence. Stan then dialed my suite number and my roommate, Robert Potts ,

answered and Stan impersonated a delivery man. This was very strange as Stan

called impersonating a delivery man on a Sunday at approximately 7:30 p.m. Mr.

Potts did not provide access to Stan, and Stan had left.

50) Shortly thereafter, Stan re-attended Mr. Bagwalla's residence again looking for

me. I have been advised by Mr. Bagwalla and verily believe that he asked Stan

to leave his premises, failing which, he will be contacting that police . At which

time, Stan threw a coffee at Mr. Bagwalla's door and left.

51) I am afraid that the Defendants will show up at my school, which will cause even

further embarrassment to me. I have alerted by professors and some school

administrative staff to not provide information regarding my classes or

whereabouts.

Communication with the Defendants:

52) On February 6, 2016, I had communication with the Defendants via email.

Attached hereto and marked as Exhibit "T" is a true copy of the email which I

had with the Defendants. The Defendants used the email address

Ironin@keroboats.com.

53) On February 6, 2016 at 12:40 p.m., I delivered an email to the Defendants

stating:

Hey,

I'm doing good. I'm doing fine. No need to worry about me. I [am]

still not ready to meet with you or talk to with you. Hope you can

respect that.

Sam

54) On February 6,2016 at 1 :10 p.m., the Defendants replied:

Thank you.

Love and miss you.

Dad, Mom, Stas, Dana and Steven

55) On February 6, 2016 at 1: 12 p.m., I replied to the Defendants' email stating:

If you want things to improve then you have to respect my wishes

and not insult people that have nothing to do with my decisions.

56) I recently read an article from the Toronto Star whereby a 21 year old university

student obtained a retraining order against her parents for very similar reasons.

Attached hereto and marked as Exhibit nu" is a true copy of the said Toronto

Star article.

57) I swear this Affidavit in support of my motion seeking to, inter alia, remove the

Websites for no improper purpose(s).

SWORN BEFORE ME at the City of Mississauga, in the Province of Ontario this 18th day of April, 2016.

Amandeep Sidhu Commissioner for Taking Affidavits

SAMUEL RONIN also known as SAM RONIN

RONIN and Plaintiff I Moving Party

RONIN et al. Defendants I Responding Parties

Court File No. CV-16-1857-SR

ONTARIO SUPERIOR COURT OF JUSTICE

PROCEEDING COMMENCED AT BRAMPTON

AFFIDAVIT OF SAMUEL RONIN also known as SAM RONIN

KEYSER MASON BALL LLP Barristers & Solicitors 4 Robert Speck Parkway Suite 1600 Mississauga, Ontario L4Z 1S1

Amandeep Sidhu (613080) Telephone No.: (905) 276-9111 Direct Telephone No.: (905) 276-0401 Fax No.: (905) 276-2298 Email: asidhu@kmblaw.com

Lawyers for the Plaintiff I Moving Party