Chilliwack

04-Apr-16

NO. S030644
CHILLIWACK REGISTRY
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
MANJIT KAUR GILL
and 0492312 B.C. LTD. doing business as
CAMY ENTERPRISES LTD.
PLAINTIFFS
AND:
NAROTAM SINGH DHANOA, SURINDER KAUR DHANOA,
689939 B.C LTD., BIR KANWAR SINGH DHANOA,
and NAVNAGEENA DHANOA
DEFENDANTS
RESPONSE TO CIVIL CLAIM

Filed by:

NAROTAM SINGH DHANOA, SURINDER KAUR DHANOA, BIR

KANWAR SINGH DHANOA (the "Defendants")

Part 1: RESPONSE TO NOTICE OF CIVIL CLAIM FACTS

Division 1 - Defendants Response to Facts
1.

The facts alleged in paragraphs 3-6 of Part 1 of the notice of civil claim are
admitted.

2.

The facts alleged in paragraph 7-58 of Part 1 of the notice of civil claim are
denied.

3.

The facts alleged in paragraph 1-2 of Part 1 of the notice of civil claim are
outside the knowledge of the defendant.
Division 2 - Defendants Version of Facts

1.

Unless admitted herein, the Defendants deny each and every allegation in the
Notice of Civil Claim and put the Plaintiffs to the strict proof thereof.

2.

The personal Defendants were never agents of the corporate Defendant. All
dealings were with the corporate Defendant.

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3.

The personal Plaintiff was fully aware of her dealings with the corporate
Defendant. All dealings were transparent and straight forward. Until the personal
Defendants son got involved, there was never any discussion about the return of
a loan or promissory note because she clearly knew about her investment in India
and did not disclose that to her son or daughter.

4.

Once her son found out he started asking questions from the personal Defendants,
and they did not disclose any information to him or anyone else, as specifically
requested by his mother.
Division 3 - Additional Facts

Nil.
Part 2: RESPONSE TO RELIEF SOUGHT
1.

The defendants consent to the granting of the relief sought in none of Part 2 of the
notice of civil claim.

2.

The defendants oppose the granting of the relief sought in all of Part 2 of the
notice of civil claim.

3.

The defendants take no position on the granting of the relief sought in paragraphs
n/a of Part 2 of the notice of civil claim.

Part 3: LEGAL BASIS

1.

The Defendants deny that they have committed fraudulent misrepresentation,

negligent misrepresentation, breach of contract, conversion, breach of trust,
breach of fiduciary duty, conspiracy, or any breach of the Business Corporations
Act as alleged, or at all.

2.

The defendants deny that the Plaintiffs have been unjustly enriched as alleged, or
at all.

3.

The Defendants deny that the Plaintiffs have suffered any damages as alleged, or
at all.

4.

In the alternative, if the Plaintiffs have suffered any damages, which is not
admitted and in fact denied, then the Plaintiffs have failed to mitigate those
damages.

5.

If the Plaintiffs have a cause of action and have suffered any damages, both of
which are vigorously denied, the Plaintiffs claims are barred by operation of the
Limitation Act [SBC 2012] C. 13.

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