Questions Prepared to Ask Jackie Friolet Young at Trial






THE CROWN SHOULD HAVE CHECKED; Witness Credibility 1. Witness Objectivity All the witnesses in the crowns case have a vested interest in the out come.


Questions Jackie Young


Good Day Mrs. Young. First, let me say, there is nothing to be afraid of; I'm not going to badger you. It's not my way to be threatening to women, my mother had been abused for years and she raised me to respect women. All we are here today to do is to determine the truth, the chain of events and what actually happened.

Has the Crown told you that it's a crime to lie in courts. That you could be sentenced to 14 years in a penitentiary if you are caught lying?

Have you talked to your hubby about what he said when he was being questioned last time we were in this court? You have not had any discussions at all, or just a few??

How old are you? What is your level of education? What do you do for a living? Have you ever told a lie before today? Have you ever been charged with a crime before?

What I'm going to do is ask you to clarify your statements to Officer Moore and to do this I'm going to have you update a time line of occurrences that you have stated have occurred. I'm going to start with your written statements and then move to what you have sworn to the Crown you will state.

Lets start at the beginning of your notes. The very first line, your notes state that you moved here in 2002. Is that true? Or false?

1. You state that you moved into your rental in July of 2002. Is this correct?

If yes: Ok, so we moved in to our residence on October 2002. Did my wife and I and our dogs move into our residence after you rented 55 Sprucedale Ave?

Ok then you moved in after us and you moved in during a month of July. Would it be correct to say you moved in July of 2003?

Ok let me update the timeline.


If no: Says she made a mistake.

So it's fair to say that the first line of your notes is a false statement.


2. You state that on New Years Eve of that year (so that would be the evening of Dec 31, 2003) you were celebrating the New Years Eve with your sister in law and father in law. Is that correct?

3. According to your notes about a half hour after the world greeted in the New Year, you and your husband were aware that I had gone outside and chopped some wood for about 15 minutes to warm my house. Can you please state exactly what you saw during that period of time and why you felt that was of concern?

If left wood there and didn't bring it in: Can you explain to me how long you stood at the window or door viewing exactly what I was doing? From your written notes it appears that you observed my activities outside for quite a period of time. Can you estimate how many pieces of wood I had chopped for fuel that cold evening?

If not at window the whole time: If no one in your house was standing and watching me the whole time you would have no way of knowing if I had brought some wood in my house and then chopped a little more for the next day, or would you? Please explain.

On page 2 of your handwritten notes you stated that your son has never worked for me or noel? Is that true? Never cut the grass? Never painted parts of a fence with white primer?

4. You state you moved into your rental in July of 2002 (well, 2003). When you first moved in it was quite hot out. Did my wife often give your two children ice pops and soda when you first moved in that hot summer?

If yes:
So New Years Eve 2003 wasn't the first encounter you had with us as neighbours is it? Would you describe for the court other encounters you had with us between July 2003 and New Year's Eve 2003.

· ice pops, soda

· Fixed Chris's computer several times

· Lent Chris computerized dictionary for dyslexia (he should still have that.)

· Played ball with Chris on occasion & listened to his life stories

· We knew your son didn't have as many friends as your daughter and he said how lonely he was.

· Your son wanted an expensive motorized toy

· We made the check out to your name so you could cash it for him so he could buy the toy. In your notes you state you do not even know my name. Can you look at the check made out to you and the Court whose name is on there? So the statement that you didn't know my name is false isn't it, Mrs. Young? (PICK UP CHECK AT TABLE)

5. Ok let's move away from 2003.

You state that the next incident I had taken pictures of your daughter and her friends saying 'I got you now and I'm putting them on the internet'. Did you actually hear this or are you saying someone told you this?

Did I in fact put any pictures of any children/kids on the internet?

Is it possible that I went out there with the camera for a different reason?



6. Since you recall this incident but can't identify a date, can you please tell the court what season in 2004 this occurred?

If yes:

Proceed below.


If no:

Fortunately I do recall that incident. It was temperate outside so that would have made it around mid summer, maybe July or August of 2004.


7. Can you please tell the court some of the activities that were occurring with your children's friends that summer, what grade they would be going into that fall, did they have a lot of friends, what types of activities they were they involved in, a few things like that.

Doesn't matter what she says.

8. Were you also aware of some of the other activities the kids were into that summer?

Were you aware that a magnetic sign was stolen off the side of my truck? And that a light bulb was removed from a light fixture over my entrance door?

Are you also aware that your husband stated that the girls removed the sign and that a young lad by the name of Dustin removed the lightbulb. That your husband had offered to pay me $20 for the loses and that I refused stating "Please try to get control of your kids and their associates"?


· In your driveway drunk and cursing?

· Making fun of other kids from your driveway?

· Leaving your property with backpacks that had plants hanging out of them and delivering in the neighbourhood?

· Making handgun motions at us when we went to the door to let them know we could see the mischief they were doing


9. You state that by telling them we would record their mischief they phoned the police. Were you surprised that the police never investigated and in your own words what was your reaction to that?

Doesn't really matter what she relates.

10. Did your husband tell you that he was afraid of the kids that your daughter was hanging out with and that he couldn't control them?

Doesn't really matter what she relates.

11. Did your husband tell you that is what he told me when I complained to him previous to that incident? And actually his words were 'they were some pretty heavy dudes'?

Doesn't really matter what she relates.

12. Your husband stated that your home was broken into three times during 2004.

What was the entry point of the first break-in.

What was taken?

What was the entry point of the second break-in?

What was taken?

What was the entry point of the third break-in?

What was taken?

13. Your husband stated that the entrance point of the break-ins were through your basement window under your back deck and that in the first break-in marijuana was taken; the second break-in clones were taken and the third break-in his Nazi stamp collection was stolen from your bedroom. Does that surprise you that he would say that?

14. Did you tell your husband that after the break-ins you were afraid in your own home?

15. Did you notify the police to investigate the break-ins as they happened and if not, in your own words can you explain why didn't you?

16. Had your husband put up a motion sensor detection security light would you have felt safer in your own home?

17. Ok, lets more on to the next incident in your written statement. That is where you discuss that I had moved my wife's car on your side of the driveway next to my Jimmy. You do not mention when this occurred, so for the timeline can you recall in a closer time frame when that occurred?

If yes and gives a date.

Ok let me add the date to the time line.


If no, or for clarification:

Ok, apparently Officer Moore attended that incident. In his Crown Brief Synopsis Officer Moore stated the incident of the 'blocked vehicle' occurred on the 4th of August 2004.

So lets update the timeline to reflect that date ok?


18. In your own words can you related what exactly occurred leading up to and including my parking my wife's car on your side of the driveway next to my Jimmy which lead to the OPP being called.

If yes: (and she talks about the disagreement that occurred around 6PM)

You state that I had been outside starting up my sawmill briefly several times and you felt that that meant that 'something was wrong with me'. Where you aware that someone had cut or broken the starter cord on my sawmill the night before?

Were you aware also that later in the afternoon I had worked on the starter mechanism in an effort to repair the damage done by the vandalism?


Do you feel that a person who is repairing a damaged starter cord might want to try starting the machine up several times to find out if it is working properly.


19. Ok, lets move on to the second part of your written statement on that incident.

Do you recall that your husband was drinking during that day and that he and I had gotten into an argument concerning his growing clones and selling them and marijuana to the neighbour kids that were being attracted to your daughter?

Do you recall that it was the first incident that day which occurred around 6PM while I was outside BBQing supper where your husband describes an alleged physical altercation similar to what you described between your husband and me?

Can you describe what your husbands behaviour is like when he has been drinking and disagrees with you? Or what his behaviour is like when he is drinking and the kids do something to annoy him.



19. Were you aware that along with the damage to my sawmill, my wife discovered that the battery to my Jimmy was dead that same day?

20. You state that I had moved my car to block your husband's car a little later in the evening. Is it possible that my wife's car was moved to your side of the driveway next to my Jimmy after I felt your husband was asleep? That I could jumpstart my Jimmy and have my wife's car moved back to my side of the driveway because it was not my intention to block your car during daylight hours? Since your husband had been drinking and as you say, was asleep at the time, there really was no pressing need for your husband to use his car until morning, isn't that correct?

21. Did you hear me tell your husband that I was looking for the jumper cables and that as soon as I jumpstarted the Jimmy I would move it?

If no: then You stated earlier that you felt that 'something wasn't right with Andy'. Once you made that statement are you saying that you no longer were interested in how your husband would manage such a situation, nor were you curious enough to watch what was occurring when you heard raised voices?


22. After your husband came out and voices were raised, did you see your husband open the door and get into my wife's car?

Did you hear your husband yell "I don't need a Jew Boy to tell me how to raise my children?"

23. Did you hear or see my wife come outside say "you two children smarten up and go to bed?" or words to that effect?


24. After this incident, isn't it true that my wife would no longer have anything to do with you or your husband? That in fact she would completely ignore you? Can you explain how that made you feel?

And that she had encouraged me and insisted that I do the same to maintain peace and avoid further confrontation?


25. In your written statement you state the next incident occurred about three weeks later. For the timeline can we put that at approximately the end of August 2004?

Ok, lets clarify that on the timeline.


26. Ok the end of August 2004 you state that I was milling some boards for fencing for my property. What time of day was that and where had I placed my sawmill in the driveway?

If daytime:

Approximately how long that day did I run the machine?

Did you also see various people come over because they were curious?

If night time:

Approximately what time was I outside running the mill and for how long? Where in the driveway was your car when I ran the mill? Were you aware that your husband came outside and said "Your getting oil spots on my car? IF NO: - Is that the type of thing your husband would ignore?



27. Can you clarify a discrepancy for the court? In your written statement you say that it caused oil spots across your hood roof and your truck. Did you have a truck?

28. Can you clarify for the court that you saw oil spots on your car?

29. Can you explain how that could occur when my mill does not use oil on the blades when milling? My mill actually uses water.

Ok let's move on to the next incident in your written statement.


30. In this statement you are saying that our dogs continually run on to your property jumping on you. Can you explain how you felt and how often this would occur that they came on your property?

Doesn't matter what she says.

Cardiff is known for its dog complaints to the town offices there. How often did you report that our dogs were running loose off of our property?

Can you explain why you didn't call the town offices?

Did you find it unusual that your husband would phone the police for other incidents and yet would not make a complaint to the Town regarding our dogs?

Can you recognize the difference between the two dogs we own? Can you describe them?



31. In your third to last incident in your written statement you mention the time when you phoned the police regarding me putting an extension on my sawmill one evening. Can you clarify for the timeline approximately when that occurred as it's not indicated in your statement?

Ok so it sounds like it was a pretty quiet winter and we've now moved to incidents toward late summer 2005. According to Officer Moore's Will State Statement to the Crown, this incident occurred on August 12 2005. We'll date that on the timeline, do you agree?

32. You state that I was at the end of my driveway running my mill. Approximately what time of day was that?


33. Did you observe me moving the sawmill and remilling something? About what time of day was that?


34. What did your husband say to you when he allegedly discovered that I had moved my mill next to his car and there was saw dust all over it?


35. Did you observe for yourself the sawdust that occurred?

36. Mrs. Young, I didn't run my mill that day, and in fact, since I've had the mill I only ran it two times on my property for two minor house projects, both time for less than a half of day.


37. Are you aware Mrs Young that the only other time's I've started up the mill on my property is for a quick start just prior to going to a job site, or after there has been vandalism to the mill and I need to see what the damage was.


38. Ok so lets clarify your on record complaint to the OPP that evening of August 12, 2005. I was assembling an extension I had just picked up on the mill for a job the next day using a ratchet and your husband was unhappy about that and was calling out the window to me and going back and forth out the porch saying he was going to phone the police and I was ignoring him. Is that correct?

You state that I was working on it at 1200AM and you phoned the police. Is that correct?

Officer Moore states that he arrived at 1200AM so it probably was earlier than that when you phoned the police correct? What time would you estimate you phoned the police?

Ok So maybe at 11:30 PM (it would probably take him a half hour to get here).

Ok so you phone the police at 11:30, Officer Allan who was the investigating officer with Officer Moore recorded in her notes that the call was 1100. (">ALLAN NOTES)

Being August 12 during the summer months about what time does it get dark in the evening?

I'd say usually at 9:30 you would need a light to see. So is it safe to assume that your husband was irate about me putting the extension on my mill from 9:30 to the time he called the police at 11PM?

During that period of time, who was making more loud noise, me with a small hand tool or your husband hollering out his window and door and slamming things on the table inside the house?



39. Immediately after this incident I spoke with Cardiff officials to determine what they feel is a reasonable time frame for 'noise' and they stated 7AM to 10PM. Have I held to that since your complaint on 12 August 2005?


40. We will now go to August 29, 2005 of your written statement.

You state that you had been out that day and when you returned around 8PM you unpacked groceries, put them on the floor of your kitchen and went in your living room to watch TV.

Can you state in your own words what occurred next?

In your notes you state that it was 8PM on August 29, 2005. Was it still light out?

Can you please describe for the court how your window is facing my back yard, your kitchen and dining area is situated and how that is in proximity to your living room?

Is there a partial wall between your kitchen and dining area and your living room?

Did you see a 'flash on the wall'?

Were you sitting in your living room watching TV with your husband or was your husband at the kitchen window hollering obscenities out the window at me while I was in the backyard with my dogs?

Would it surprise you Mrs Young that there were no pictures taken of your daughter but only of your husband's abusive behaviour at your kitchen window?



41. Let's move on to when the police arrived. Do you recall which OPP Officer's arrived that time and approximately what time of day that was?


42. Are you aware that based on your husbands accusations the police officer's checked my digital camera and my computer for pictures taken that evening?


43. You report in your written statement that I told your husband that I would put his picture on the internet. Can you state the reason I told your husband I would put his picture on the internet?


44. Prior to this incident how many times did you observe your husband throwing rocks at our vehicles, my dogs and us? Did you ever hear or observe your husband trying to get me to not ignore his harassment? Did you ever hear him say he would kill my wife, my dogs, or me?

Are you saying that while you observed everything else your husband is reporting that you never saw him attempt assault us and our pets with rocks?

Mrs Young do you feel it is a good example for your children for a father to holler such things as 'Fuckin retard', 'Jew Boy' and throw rocks at people and their pets when they are on their own property involved in activities that do not involve surrounding neighbors?

Mrs. Young, how many people that you know will throw rocks at dogs they state they are afraid of?

Mrs Young are you aware that the reason that I told your husband that he would have his picture on the internet was directly related to his abusive behaviours toward us and our pets?

(AUDIOS rocks2.wav, death threats also admits not talking.wav)



45. In your statement you say that the officer's stated they 'saw the pictures'. Did they state that they saw pictures of your daughter?

At the time that the officer's left our home after going through our digital camera and computer did they go back, as they told us they would do, and tell you there were no pictures of your daughter taken and that there were only pictures of your husband?

(MIHELL'S Occurrence Summary)



46. Mrs. Young the next morning your husband accosted my wife outside the Cardiff Corner Store demanding pictures of your daughter from my wife. Did he tell you he had accosted my wife?

Mrs. Young does your husband take out his anger on you and your children when he is angry about something - either physically or more subtly by word or intimidation?

Mrs. Young was your husband drinking heavily or doing drugs during that period?


47. Mrs. Young did I do what I had told your husband I would do about his abusive behaviours toward my wife, my pets and me and put his picture on the internet?

Was your picture on the internet? Was your daughter's picture on the internet?

Why do you think only your husbands picture was put on the internet?



48. You state that the next day, so that would be August 30, 2005 I began to install a motion sensor security light on my garage. We'll go over how you described that in your own words.

You state that it is a light tech video camera and a super bright light.

Did you see the video camera and what did it look like?

Were you aware that your husband was vandalizing our property, in particular doing damage to our Jimmy either because he told you he was or you observed him doing that?

(4 PICTURES)

Were you aware that your husband damaged my sawmill?

(1 PICTURE OF BUMPER)

Were you aware that your husband sat and waited by your windows until I arrived home from work and then would yell out the window and throw rocks at me?

Where you aware that your husband was doing this by coming out his side door and also by coming out the back door and coming down off the back porch right next to the garage either because he told you or you observed him doing so?

Mrs. Young, if this were occurring to you, where would you think you would place a motion detector light on your property?

What would be more intrusive under the circumstances, to place a spotlight that stays on all night or a motion sensor that comes on for ten minutes when there is someone near your car?


Did you KNOW, SEE OR UNDERSTAND your husband installed a spot light on the side of your home?

Just above several cans of fuel?

What was the purpose of this light?

Was it on a dimmer, or did it stay on all night?

Why did you take it down?

(1 PICTURE THEIR YARD LIGHT)

Did you know your husband was cautioned that his tampering with our security light could start a fire?

(1 PICTURE FIRST TIME YOUNG BROKE LIGHT)


49. You state that I was installing the light on August 30, 2005 and that the light comes on and you don't like that. On the next evening the police were phoned by us because your husband came onto my property, assaulted me on my property with a light he had broken while I was still installing the motion detector security light.

Mrs. Young, the sensor light did not go on the previous night because I had not finished installing it. Can you explain to the court how it can come on annoying you when that had not even occurred yet?

Do you feel that you have a right to trespass on another persons property and threaten a person on their own property based on what you think 'might' happen?

Do you feel that you have a right to trespass on another person's property when you have been told to get off their property?

Do you feel that your husband has a right to trespass on another person's property when told repeated to stay on his own property?

Can you tell me the date that you wrote this handwritten statement?

Who was with you when you wrote this handwritten statement?

Who did you give it to and when did that occur?



50. If we move on to the end of your written statement you say that after August 30 we allow our dogs to jump on you. How many times are you alleging that this occurred after August 30?

You state that we installed a video camera that might record your activities so we could show the police what had been occurring. Can you think of any reason a person would jeopardize their case against your husbands activities by then allowing their dogs to jump all over you?

Since the police attended both our residences numerous times by this point did you notify the police? Did you notify the town that our dogs were jumping on you? In your own words, why didn't you? Any other person could not have hesitated.



51. You state that one of our dogs is very aggressive and growls and barks at you.

Which dog is that?

It's usually my wife who takes the dogs out the side door and into the back yard to relieve themselves, how many times has this occurred either before or after August 30?

Can you explain what aggressive behaviour the dog has done?

Did you phone the police or the town offices?

How many times has the dog growled at you or your children?

Did you phone the police or the town offices?

Are you aware that that dog is old, has hip dysplesia, and has very little interest in other people?

Do you throw rocks at that dog when she in on our property with us in attendance?

Is the dog let loose on our property without us in attendance?

Isn't it a fact that the only time that dog growled was once and that was when your husband was on his porch hollering at us swinging a shovel saying he would beat their heads in when we were bringing her into the house after she relieved herself in the backyard?


(AUDIO fordickson.wav)

Do you think it surprised your husband that she only gave one grunt type of growl and then ignored him and came into the house with us?

If you were in fact afraid of this allegedly aggressive, vicious dog would you stand outside hollering, throwing rocks at her?

Mrs. Young, isn't it easier when you can't get a neighbour to do anything criminally wrong then it is easier to have people believe that a dog is aggressive. Isn't it more truthful to say that your husband's actions and behaviours were louder, more aggressive and disruptive than that dog ever was?


If no: Then we can certainly agree to disagree with that!


52. I only have a few more questions and then I think we are done.


53. You have stated that next we began to put a fence down our driveway on our side of the property.

Approximately how soon after your statement about the dogs did this occur?

Were you happy to see this since you state our dogs were such a nuisance?


54. You state that we dug very deep holes and left them there. Is that true?

How many holes did we dig? How long were the holes left there? Did you see that the hole was approximately 12 inch wide? How did you determine how deep the hole was, did you go outside and check? Did I leave the holes unattended? Mrs. Young did you see my wife and I outside using a post hole digger and a rod doing a test hole to determine if there was any pipes that would be broken if we placed the fence where was intended to put it? Mrs. Young after we did the test hole we immediately covered the hole up. It was never a danger to you or your children even if you had again trespassed on my property, isn't that a fact. My wife insisted we do that because she did not want a potential lawsuit.


55. My last questions have to do with an incident that is not in your handwritten notes but is included in both Officer Moore's victim statement and the Crown's paperwork that you have informed the Crown that you will say.


56. You alleged that on October 11, 2005 I pointed a cocked and loaded crossbow at you.

Approximately what time do you think that occurred?

While the time is not stated in the Crown's Will Say statement Officer Moore has placed the time of the occurrence as 2230 hrs. This is stated in his General Occurrence Report that reported on 11/25/2005 at 2016. Do you agree with the time?


57. Can you please tell the court in your own words what you saw?

Do you wear glasses?

When was the last time you had an eye test?

Does anyone in your family wear eye glasses?

You state I was standing by the garage, is that so?

Your husband told the court earlier that the light stayed on all night, and that really bothered you is that true?

Where saying i was standing?

Ok so you are stating that the light was on and you are telling the court you feel it was me because even though it was dark out there was my security lite was on? And it was a bright light, right?

Have you even heard the phrase or saying "blinded by the light" Play song.

Is it possible you were blinded by the light?

Did you have a chance to have a short conversation this Noel since we were in court? Did you say the we have a lot of enemies. Gosh I'm hurt, i didn't know that.

Can you tell the court why that is, and who these enemies are? Could it be possible that one of these unnamed enemies has white skin dark hair is about 5. 8"? Is it possible that one enemies fooled you into thinking it was actually me? Is that at all possible. Ok I see you are telling this court while everyone else in society make mistake, you are smarter and don't make mistakes.

(MEMORY & RECALL NOTES)



58. Where was I when you think you saw me pointing a cocked and loaded crossbow at you?

In Officer Moore's statement in his Occurrence report on November 25, 2005 he reports that I was at the side of my garage when this occurred.

Can you estimate what the distance was between where you stood at the window and where I was at that time?

Are you a wasteful person?

Are you a rich person?

So you know the value of a dollar.

On the 11 of October, at 2230 it was 7.7 degrees above freezing. In Bancroft Cardiff is usually 2 degrees colder. But lets say it was 7.7. It's cold.

Do you have money throw away?

So you would have closed your windows? Correct?

So you would have identified me through a screen, and two panes of glass with condensation on it?

Do you drink? Were you drinking on that night?


At 2230 how well could you see from your window?

If the security light was on then:

So you could see me very clearly is that correct? I guess on that evening the light wasn't pointed directly at your porch then.


Did you feel threatened?

Did you feel scared?

Did you feel that you were in imminent danger?

Can you please describe the crossbow?



59. My wife owns a long bow and I own a crossbow. The crossbow is broken and has no string.

Can you explain to the Court how there can be a cocked and loaded crossbow without the string or arrow?


60. You state that you advised your husband and he went to the door and said, "You'd better not miss".

How'd that make YOU feel???

I know I would have hell to pay from my wife if that were my reaction.


How many times have I done that to you before? Really just once? That may be odd. Usually when folks break the law and get away with it, they tend to do it over and over until they get caught. A good example of this is when your Spouse admitted to Noel and I he scratched the hell out of my truck and didn't get caught and punished. He then kicked it right in front of us leaving a big dent.

(Young damaged Jimmy door1 PICTURE DENT JIMMY)

Did you happen watch that from your window?

What about calling me names using a bullhorn on other occasions?

Do you own a bullhorn? That's unusual electrictronic device.

Most folks I know would have a tape recorder or camera that sort of thing?

What is it usually used for do, you do crowd control or lead protest rallies? Or is it used for other things?



61. How many times would you say prior to this alleged incident did your husband or I phone the police to attend to our homes as a result of complaints?


62. Did you immediately call the police that evening that you allege that I threatened you with a crossbow?

Can you explain for the Courts why that incident was not important enough to you to phone the police when it allegedly occurred?

Mrs. Young do you feel that a reasonable response by most people to such an occurrence considering all the other incidents would be to phone the police immediately not wait until months later when your husband will be arrested to report it?


Do you drive?

So if Mr young was sent to jail for his actions, that would cause you more then a little bit of a hardship wouldn't it?

Would you agree that at one point we got along fairly well?

That your husband and myself even talked about a part time job for him working on my sawmill?

Were you angry with me because I wouldn't hire your husband under the table?


64. Can you explain in your own words why in the hand written notes, you fail to include a date of the alleged incident and in your Will State statements you are able to not only to state the date but the time. Human nature is such that as time passes memory fads or get worse. It seems yours gets better, that flies in the face of common sense and reason or real world experience.




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