Precedent Statement of Claim A - Bogoroch & Associates

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IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVENAGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IFYOU WISH TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGALFEES, LEGAL AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCALLEGAL AID OFFICE.Issue Date:Issued by:Local RegistrarAddress ofCourt Office:th393 University Avenue, 10 Fl.Toronto, ONM5G 1E6TO:******** corporation123 StreetToronto, Ontario123 456
-3-CLAIM1. The Plaintiff claims:a. payment of long-term disability benefits at the rate of $1,932.82 per monthfrom September 15, 2003 for the duration and extent of the Plaintiff’sdisability as provided for in group policy of insurance number ******;b. a declaration that the Plaintiff is totally disabled and entitled to payment oflong-term disability benefits for the duration and extent of her disability asprovided for in group policy of insurance number ******;c. damages for mental and emotional distress in the amount of $500,000.00;d. punitive and/or aggravated and/or exemplary damages in the amount of$1,000,000.00;e. prejudgment interest pursuant to the provisions of the Courts of JusticeAct, R.S.O. 1990, c. C.43, as amended;f. her costs of this action on a substantial indemnity basis together withapplicable goods and services tax payable pursuant to the provisions ofthe Excise Tax Act, R.S.C. 1985, c. E-15, as amended;g. such further and other relief as to this Honourable Court may seem just.2. The Plaintiff, ********************, resides in the City of Toronto, in the Province ofOntario, and was at all material times an “insured person” within the meaning of thepolicy referred to in paragraph 4 below.3. The Defendant, ******** corporation (hereinafter referred to as “******** corporation”),is a body corporate duly authorized to carry on business in the Province of Ontarioand was at all material times engaged in the business of insurance underwriting.4. In consideration of the premium specified, the Defendant, ******** corporation,
Page 1: (PRECEDENT STATEMENT OF CLAIM “A
Page 5 and 6: -5-disability benefits which ******
Page 7 and 8: -7-were the part of a systemic corp
Page 9 and 10: -9-25. The Plaintiff further claims
Page 11: ******************** and ******** c

Precedent Statement of Claim A - Bogoroch & Associates

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