Submissions - Crown R. v. D. Townsend page 41

…stop until he’s made his point. We’ve seen that and in my respectful submission what he was doing on December 8^th was, he was making a point to Mrs. Broadbent. He resented the fact he wasn’t getting his own way. He couldn’t have it maintained as he saw fit, he couldn’t have his idiosyncratic point of view indulged. The one thing that he had was a right to go over, drive over that right-of-way and that wasn’t going to be taken away from him just because she’s standing there. In my respectful submission, what he did on that day is very consistent with what Mrs. Brandt indicates happened to her. That he’s somebody who in the past takes his frustrations out on his neighbours with a motor vehicle. Your Honour. I’m going to stop here. (then Judge Lajoie held up the pictures he wanted to use “for my (his) purposes” and indicated that the Crown should include them in the submissions) If the Court wishes to direct me to any points in the evidence or any issues before the Court, I’m happy to address them, but in my respectful submission, the Crown has proven its case beyond a reasonable doubt on this count before the Court. (at the Judge’s persistence the Crown ignored his admission that I took the pictures lawfully for a record and he included them in his submissions)