Court File No.

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IN THE COURT OF QUEEN'S BENCH OF COUR DU BANC DE LA REINE DU
NEW BRLINSWICK NOUVEAU-BRLINSWICK

TRIAL DIVISION DIVISION DE PREMIERE INSTANCE

ruDICIAL DISTRICT OF MONCTON CIRCONSCRIPTION JUDICIAIRE DE

BETWEEN: ENTRE:

rnl*t olvtsloN
THERESA JONES, fioNcTor{. N.B.
rrueomeolgrEneo

Plaintiff MAY I6 2016 Demandeur

gP,uI_Dg-BSfe.fr mE LA REnrE
-and- -et orv. o e
-pne ru} eriEi#6rfni$E
r

N..8.

BENOIT CHARRON,

Defendant. Defendeur

NOTICE OF'ACTION WITH AVIS DE POURSUITE ACCOMPAGNE

STATEMENT D'UN EXPOSE DE LA DEMANDE
OF CLAIM ATTACHED (Formule 16,{)
(Form 16,{)

TO: Benoit Charron DESTINATAIRE: le d6fendeur

Wainwright, Alberta susmentionn6
Address unknown

LEGAL PROCEEDINGS HAVE PAR LE DEPOT DU PRESENT

BEEN COMMENCED AGAINST YOU BY
FILING THIS NOTICE OF ACTION
WITH STATEMENT OF CLAIM
ATTACHED.
If you wish to defend these
proceedings, either you or a New Brunswick
lawyer acting on your behalf must prepare your
Statement of Defence in the form prescribed by
the Rules of Court and serve it on the Plaintiff
or the Plaintiffs lawyer at the address shown
below and, with proof of such service, flle it in
this Court Office, together with the filing fee of
$s0.00,
AVIS DE POURSUITE ACCOMPAGNE
D'UN EXPOSE DE LA DEMANDB, LINE
POURSUITE JUDICIAIRE A NT'E
ENGAGEE CONTRE VOUS.
Si vous ddsirez pr6senter une d6fense
dans cette instance, vous-m0me ou un avocat
du Nouveau-Brunswick charg6 de vous
reprdsenter devrez r6diger un expos6 de votre
d6fense en la forme prescrite par les Rdgles
de procddure, le signifier au demandeur ou d
son avocat d I'adresse indiqude ci-dessous et
le d6poser au greffe de cette Cour avec un
droit de d6p6t de $50 et une preuve de sa
signification,
(a) if you are served in New Brunswick,
WITHIN 20 DAYS after service on you
of this Notice of Action With Statement of
Claim Attached. or
(b) if you are served elsewhere in Canada or in
the United States of America, WITHIN 40
DAYS after such service. or
(c) if you are served anywhere else, WITHIN
60 DAYS after such service.
If you fail to do so, you may be deemed
to have admitted any claim made against you,
and without fuither notice to
JUDGMENT MAY BE GIVEN AGAINST
YOU IN YOUR ABSENCE.
You are advised that:
(a) you are entitled to issue documents and
present evidence in the proceeding in
English or French or both;
(b) the Plaintiff intends to proceed in
English language; and
(c) your Statement of Defence must indicate
the language in which you intend to
proceed.
If you pay to the Plaintiff or the
Plaintiffs lawyer the amount of the Plaintiffs
claim, together with the sum of $100 for the
Plaintiffs costs, within the time you are
required to sere and file your Statement of
Defence, further proceedings will be stayed or
you may apply to the court to have the action
dismissed.
(a) DANS LES 20 JOURS de la signification
qui vous sera faite du present avis de poursuite
accompagne d'un expose de la demande, si elle
vous faite au Nouveau-Brunswick, ou
(b) DANS LES 40 JOURS de ta
signification, si elle vous est faite dans une
autre region du Canada ou Canada ou dans
les Etats-Unis d'Amerique, ou
(c) DANS LES 60 JOURS de la
signification, si vous est faites ailleurs.
Si vous ometlez de le faire, vous
porrrez 6tre r6put6 avoir admis toute
you, demande formul6e contre vous et, sans autre
avis, JUGEMENT POURRA ETRE
RENDU CONTRE VOUS EN VOTRE
ABSENCF],.
Sachez que:
(a) vous avez le droit dans la prdsente
instance, d'dmettre des documents et de
prdsenter votre preuve en frangais, en
anglais ou dans les deux langues;
the (b) le demandeur a I'intention d'utiliser la
langue et
(c) I'expos6 de votre d6fense doit indiquer la
langue que vous avez f intention d'utiliser.
Si, dans le delai accorde pour la
signification et le depot de I'expose de votre
defense, vous payez au demandeur ou a son
avocat le montant qu'il reclame, plus $100
pour couvrir ses frais, il y aura suspension de
l'instance ou vous pouffez demander a la cour
de rejeter l'action.
THIS NOTICE is signed and sealed CET AVIS est sign6 et scell6 au nom
for the Court of QuE4n's Bench by de la Cour du Bank de la Reine par
, lla^ e !{) ff ,', h- . ,t , Moncton, greffier de la Cour a ce
Clerk of the Court at Moncton, on the mai2016.
/6n?ay 2016.

eau de
Cour Greffier

Address of court office: Adresse du greffe:

Moncton Law Courts

145 Assomption Blvd,
Moncton, NB Canada
ElC OR2
 STATEMENT OF CLAIM

1. The Plaintiff, Theresa Jones, is a resident of the City of Dieppe, in the County of
Westmorland and Province of New Brunswick.

2. The Defendant, Benoit Charron, is a resident of the Town of Wainwright, in the Province of
Alberta.

BACKGROLIND
3. Throughout the period of January l7th,2014 to May 20th, 2074 inclusive, a man, now known
to the Plaintiff as Benoit Charron, hereinafter the Defendant, represented himself to the
Plaintiff using a fraudulent identity, and with other deceptions and concealments of the
material facts he entered the Plaintifls life and, throughout the period of time herein
mentioned, by his conduct and in all the circumstances, did criminally harass, sexually
assault, and threaten the Plaintiff, Theresa Jones.

4. After the Plaintiff came to the realization of the Defendant's true identity, on or about May
l8tn, 2014, she took immediate measures toward attempting to hold the Defendant
accountable for what she believed to be crimes committed against her by the Defendant.

5. On May z}th,2}l4,the Defendant resumed contact with the Plaintiff and he explained to her
the situation while, for a period of time, he attempted to maintain his deceptions he had
maintained for the previous four months. Throughout the course of the various
conversations that ensued, however, the Defendant became aware that the Plaintiff had
discovered his true identity, that the Plaintiff had sent a communication to a person she
mentioned to be "Katia", and that the Plaintiff stated to the Defendant that she was afraid of
him and of what he might be capable of doing in light of the facts of which she had just
recently become aware.

6. After the Defendant became aware of the above mentioned facts, the Defendant became
angry and engaged in threatening conduct and, the Plaintiff states, the Defendant caused the
Plaintiff to receive a threat causing her to fear for her safety and/or that of her family if she
were to continue to pursue any actions that might cause the Defendant any "trouble".

7. On the afternoon of January l\,2074, the Plaintiff drove her son, Ross Clowes (hereinafter
RC) from her home in Harlland, New Brunswick, to Fredericton, New Brunswick, in order
for RC to catch his early morning scheduled flight at or about 6:00 a.m. on January 12,
2014, out of the Fredericton International Airporl.

8. The PlaintitT states that, during the drive to Fredericton, afbresaid, driving conditions were
extremely dangerous and stressful and took approximately 3 % hours. The fact is that, after
the Plaintiffexited the highway behind a plow truck at the Nackawick, New Brunswick exit
she was informed by the plow truck driver that the highway was closed to through traffic
 due to the extreme weather causing ice buildup and resulting in multiple accidents including
but not limited to emergency and maintenance vehicles.

MATERIAL FACTS

9. The Plaintiff states that, at or about 9:30 p.m., on January 11,2014, she took a taxi from her
oldest son's apattment in downtown Fredericton, aforesaid, to Dolan's bar, hereinafter the
bar, in Fredericton, aforesaid, and that she sat by herself to relax and to watch the live band
while she sipped her beer. As the bar became crowded the Plaintiff twice relocated to a less
crowded seating area.

10. The Plaintiff siates that she did not have her cell phone with her on the evening of January
11,2014.

11. The Plaintiff states that the Defendant approached the Plaintiff on several occasions while
she sat by herself in the bar, aforesaid, and that on each occasion the Defendant attempted to
initiate conversation with the Plaintiff, it being the first time the Plaintiff ever saw andlor
met the Defendant.

12. The Plaintiff states that she questioned the Defendant as to how he was able to attend the bar
without his wife or girlfriend. In response, the Defendant expressly stated to the Plaintiff
that he was separated from his wife, that he had been since the summer of 2013, and that he
was single and not involved with any woman.

13. The Plaintiff states that, at all material times, the Defendant did make false and misleading
statements and representations and did represent himself to be a single man who was not
engaged in any relationship with any woman.

14. In fact, the Defendant, at all material times, had a common law wife from whom he was not
separated.

15. The Plaintiff, Theresa Jones, states that, at all material times hereto, she did rely on the
Defendant's false and misleading statements and representations as to the facts and
circumstances known to the Defendant at the time, and the Plaintiff did consider same to be
facts ofreality and did base her decisions on said representations.

16. The Plaintiff states that the parlies conversed and listened to music for a period of time,
during which time the Defendant flirted with the Plaintiff by expressing his attraction to the
Plaintiff, both verbally and through his body language and actions.
 t7. Early in the morning of January 12,2014, the Defendant expressly stated to the Plaintiff his
desire that she provide him the opportunity get to know each other better and he did express
his desire to explore the possibility of commencing a relationship. The Defendant then
requested the Plaintiff to provide him with her contact information.

18. The Plaintiff, Theresa Jones, states that, pursuant to the Defendant's representations upon
which she did rely, aforesaid, the Plaintiff provided the Defendant with her email address
and the last four digits of her home phone number. The Plaintiff states that she informed the
Defendant that he would locate the first three digits of her home phone number by searching
her local telephone listings of Hartland, aforesaid.

19. The Plaintiff states that the Defendant, again, initiated fuither contact with the plaintiff
when he called her residence, (506) 315-4599, on Monday, January 13, 2014, at
approximately 6:00 p.m.

20. Throughout the week of January 13,2014, the Defendant continued to initiate and pursue
contact with the Plaintiff by calling her residence, by calling her cell phone and by email.
During those communications the Defendant continued to expressly state his increased
interest in the Plaintiff and his increased desire that he and the Plaintiff get to know each
other better.

2t. The Plaintiff states that, on one occasion wherein the Defendant contacted the plaintiff by
teiephone, the Defendant expressed to the Plaintiff his intense emotional and physical
attraction that he felt toward the Plaintiff and the Defendant implored the Plaintiff to permit
him to travel to the Plaintiff s residence to meet with her.

22. The Plaintiff states that, at all material times hereto, the Defendant increasingly and
persistently maintained his false and misleading statements and representations of the facts
and circumstances known to him at the time.

z). The Plaintiff states that the Defendant arranged to obtain the Plaintiff s residential address,
specifically,7625 Route 5, Upper Brighton, New Brunswick, and the Defendant first
travelled from Oromocto, New Brunswick, or there about, to the Plaintiffs residence.
aforesaid, on or about January 77,2014.

24. The Plaintiff states that, during the evening on or about January 17, 2074, on the first
evening the Defendant entered the Plaintiff s dwelling, while the parties were engaging in
casual conversation as the Plaintiff prepared dinner, the Defendant initiated a conversation
with the Plaintiff in which he asked the Plaintiff if she hacl ever "cheated,, u,hile in a
committed relationship.

6
25. The Plaintiff states that she replied to the Defendants inquiry and that she expressly stated to
the Defendant that she had the right to any material facts, in fact she stated it was her legal
right to freedom of choice as it related her sexual autonomy. The Plaintiff also expressly
voiced to the Defendant that she, and every human being, has the legal right to state their
limitations on who is permitted to touch them and under what circumstances, expressly as it
pertains to any and all sexual contact andlor activity.

26. The Plaintiff continued to express to the Defendant more of her deep seated views as they
related to a person's right to make informed decisions based on the reality of facts, and the
Plaintiff also expressed to the Defendant, and she stressed to him the vital importance of
informed consent as it relates to sexual activitv.

27. The Plaintiff states that, during her response to the Defendant, aforementioned, she
expressed to the Defendant how some of her previous relationships had ended due to
deceptions and concealment of the facts and how those actions caused her a great deal of
emotional and psychological suffering. The Plaintiff expressly stated to the Defendant that,
due to her past experiences, she insisted on being provided true, honest, realistic facts ofthe
circumstances known to the Defendant at the time, the fact is the Plaintiff stated to the
Defendant that it was her legal right to said facts in order to make informed decisions and
choices as it related to her consent.

28. Despite the Plaintitf s express insistence on her legal right to informed consent, and despite
her insistence of not permitting any man who is in any relationship with any woman to
become sexually involrred with her, the Defendant continued to misrepresent to her that he
was separated. The fact is the Defendant falsely stated to the Plaintiffthat his "ex-wife" had
been caught cheating on him which, the Defendant stated to the Plaintiff, caused him
emotional and psychological suffering.

29. Based on the facts and circumstances known to the Plaintiff at the time, and based on the
above mentioned conversation, together with the Defendant's continued deceptions,
intentional concealment of the facts and misrepresentations, the Plaintiff permitted the
Defendant to remain at her residence for the remainder of the weekend so as to continue to
get to know each other.

30. At all material times hereto, the Defendant was willfully blind to the Plaintiff s express lack
of consent to any and all sexual contact and/or activity with him, in that the Defendant
continued to deliberately misrepresent and to conceal from the Plaintiff the true
circumstances and facts as they related to her express limitations and restrictions to any and
all sexual contact andlor activity, the Defendant deliberately, maliciously, with
premeditation doing so for the express pur?ose of deceiving the Plaintiff into providing
consent based on the aforementioned deceptions and concealments of the Defendant.
31, Throughout the period from the January ll,2Ol4 up to and until approximately May 18,
2014, at all material time under false pretenses, disguised under a fake identity, the
Defendant continued to misrepresent the facts and circumstances to the Plaintiff, and he
continued to return to the Plaintifls residence regularly on the weekends and the Defendant
did Sexually Assault the Plaintiff in her residence when he did Abuse his Position of Trust
and when he did Fraudulently identify himself and the facts of the circumstances to her by,
in part but not limited to, disguising himself as Benoit Lefebvre, a single man, separated
from his wife. The Defendant, in so doing, throughout the period of time, above mentioned,
with full knowledge, or ought to have known, or was willfully blind, did sexually assault
and did harass the Plaintiffby, but not limited to, telephone calls, text messages, emails, and
skype.

32. Throughout the period of time from January 17th,2014 up to and including May 20th,2O:,4,
hereinafter the period of time, the Parties engaged several conversations and
correspondences relating to the Parties' initial conversation on the evening of January 17th,
2014, aforementioned, wherein the parties mutually agreed upon a standard of care owed
toward each other respecting their reliance on Trust in the other and, as the Plaintiff stated to
the Defendant, her reliance on that Trust caused the Defendant to owe her a duty of care.

JJ. The Parlies, throughout the period of time aforementioned, also discussed in depth the
impodance the Plaintiff placed on her right to make informed decisions based on the reality
of circumstances as they were known to, and as they become known to, the Defendant.
Nevertheless, the Defendant continued to fraudulently misrepresent his identity and the
material facts as they related to the Plaintiffls explicit consent for the purpose of
manipulating her into continuing to permit the Defendant to attend her residence. The
Defendant, in fact, took steps to conceal his true identity from the Plaintiff when he stated
that his name was Benoit Lefebvre, when he stated that he did not have a facebook profile
account, and when he stated that he was separated and single.

34. In fact, at all material times, the Defendant did not go by the name Benoit Lefebvre nor has
he ever, the Defendant did have a facebook prohle account in under his true identity, Benoit
Charron, and he was in an ongoing common law relationship.

35. On or about the weekends of January lTrh-l9th, January 24th-26th, January 31't-February 2nd,
February 14th-16t1', February 27't-23'd, and the night of February z}th,2.ol4, the Defendant
returned to the Plaintiff s place of residence, represented himself to be Benoit Lefebvre, a
man separated from his wife since prior to June of 2013, and despite the Plaintiff s explicit
and repeated statements that she refused to engage in sexual activity andlor relations with
any man involved with another person, the Plaintiff consented to sexual activity including
sexual intercourse with the Defendant based on her reasonably-held belief that the
representations expressly and implicitly made by the Defendant were true.
36. The Plaintiff states that, throughout the period of time, the Defendant represented to the
Plaintiff, on several occasions, that he had previously associated with members of the Hell,s
Angels, the Defendant stating he maintains a relationship with the son of the Head of the
Sorel Chapter of the Hells Angels.

37. The Plaintiff states that, throughout the period of time, the Defendant also represented to the
Plaintiff that he maintains friendships with individuals who are capable of causing other
people to disappear, the Defendant expressly stated to the Plaintiff that no one would ever
know where they were or what happened to those who disappeared.

38. On or about April, 2014, the Plaintiff told the Defendant about an exercise that her son, RC,
was scheduled to attend in May, 2014. Later on in April, 2014, the Defendant stated to the
Plaintiff that he too was scheduled to attend the same exercise as the Plaintiff s son was
scheduled to attend. After stating he would be attending the same exercise as the plaintifls
son, and after having previously stated to the Plaintiff that he was associated with Hells
Angels and has friends capable of making other people "disappear", the Defendant stated to
the Plaintiff that he planned to, and he specifically stated the word, "kidnap" her son during
the exercise in May, 2014. The Defendant expressly state to the Plaintiff that her son would
have no choice in the matter and he also stated that no one in RC's immediate circle of co-
workers and/or employers would be aware of RC's departure, the Defendant stating to the
Plaintiff that RC's disappearance would, in fact, be a cause for alarm in RC's camp. The
Plaintiff states, and the fact is, the Defendant stated his seniority would permit him to
accomplish such an act with impunity, and that he would do so for the purpose of
introducing himself to the Plaintiff s son.

39. At this point, the Plaintiff

states that she became uncomfoftable with the Defendant's
statements and she expressed her discomfort to the Defendant that she didn't approve of
such actions.

44. On or about May 18th, 2074, the Plaintiff noticed a Facebook account having a picture
associated with that profile that appeared to depict the Defendant in a similar picture he had
shown to the PlaintilT once. The Facebook account was made under the name "Benoit
Charron"' Upon sclccting the profile, the Plaintiff discoverecl that the account, under the
name Benoit "Charron", was, in fact, the facebook profile account of the man who, for the
past four months, had been representing himself to the Plaintiff as Benoit "Lefebvre". a man
who did not have a facebook profile, who was separated and single.

4t. On or about May 19th, 2014,the Plaintiff contacted her son, RC, to warn him with respect to
the Defendant's threats to abduct him. aforementioned.

42. On or about May 1Sth or 19th, 2014 the Plaintiff contacted the person listed on Mr. Charron's
Facebook profile as Katia Beaulieu, the Plaintiff states that she rccalls the Defeldalt
 referred to his "ex-wife" by a similar first name once, however the Plaintiff states the
Defendant never mentioned his ex-wife's last name to her.

43. On or about May 18th and 79th,2014, the Plaintiff states that, after the time she discovered
the Defendant's fraud, and breach of trust, the Plaintiff made an attempt to contact the
woman she believed to be the Defendant's "ex" wife, specifically the woman named Katia
Beaulieu from the Defendant's facebook Friend's list, the Plaintiff states it was her desire
that the Defendant's ex-wife would possibly help her gain insight into the circumstances that
she was current faced with, specifically a different reality the Plaintiff had just recently
become aware when she discovered the true identity of the Defendant.

44. The Plaintiff states, and the fact is, that on or about May 20th, 2014, the Defendant contacted
the Plaintiff and, for approximately an hour, attempted to continue his fraud. When
confronted with the fact that the Plaintiff had contacted Katia, the Defendant became angry
and subsequently made attempts to stop the Plaintiff from exposing his actions any fufther,
the fact is, the Defendant implied threats of imminent harm to the Plaintiff if and/or when
she did not agree to his demands.

45. Had the Plaintiff been aware of the Defendant's true identity and the material facts of his
circumstances she would never have indicated that she consented to engaging in sexual
activity of any kind with the Defendant. Further, had she become aware of the Defendant's
true identity and of the material facts of his circumstances at any point during the Parties'
encounters, she would have discontinued all contact with the Defendant immediately and,
the fact is, the Plaintiff would not have consented to any further contact, sexual or otherwise.

46. The Defendant's representations that: (i) he was single; (ii) he expressly implied he would
never intentionally inflict emotion or psychological harm on anyone; (iii) his express
agreement to inform the Plaintiff as to any and all material facts as they related to her
consent; and (iv) by identifying himself as Benoit Lefebvre while taking measure to conceal
his true identity, were deliberate, willful, and conscious distortions of the truth. The
Defendant made those false statements and representations with the knowledge that they are
untrue. The Defendant intended to deceive the Plaintiff. The Defendant intended that the
Plaintiff would rely and act upon his false statements and representations. The Plaintiff did
so and, solely based upon the Defendant's false statements and representations herein
mentioned, proceeded with sexual intercourse and other sexual contact and/or activity. The
Defendant brought about sexual activity by deception. The Plaintiff did not give her
informed consent to the sexual activities in which the Parties engaged during the relevant
period of time. As a result, the Plaintiff has suffered damages.

47. From January 11, 2014 to May 20, 2014, the Defendant intentionally and fraudulently
misrepresented his identity and marital status to the Plaintiff.

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48. The Plaintiff did not give her informed consent to any sexual activity, including intercourse,
with the Defendant. Specifically, she did not consent to any sexual activity with the
Defendant's specific identity; that is, the man who is identified to be Benoit Charron, who
was, at all material times, identified by the Government of Canada as being the common law
spouse of Katia Beaulieu.

49. The Plaintiff states, and the fact is, she expressly enquired of the Defendant as to whether he
was single and agreeable to her requirements of informed consent because she had already
made the clear and conscious choice not to have sexual relations with any man involved
with any other person. The deceptions by the Def'endant deprived the Plaintiff of the benefit
ofthat choice.

50. The Plaintiff states that as a result of the Defendant's false and misleading statements and
representation, and as a result of the Defendant's deliberate concealment of the material
facts in which the Plaintiff specifically and expressly did inquire, the Plaintiff states that,
during the relevant period of time, she did not give her informed consent to the Defendant to
any sexual activity including intercourse during that relevant period of time.

51. The sexual contact was therefore without consent and constitutes sexual battery.

52. In the alternative, if the Plaintifls consent was valid at the time given, it has been vitiated
by the Defendant's pervasive fraud respecting his both his identity and the material facts
known to him at the time. The Plaintiff would not have consented to sexual contact and/or
activity including sexual intercourse had she known the true state of affairs. The Plaintitf s
consent was procured by the Defendant through his fraud, manipulation of the material
facts, deceptions and concealment of the material facts. Accordingly, that consent was
vitiated.

53. In the alternative, if the Plaintiff s consent was valid at the time given, it has been vitiated
by the Defendant's abuse of his position he placed himself in in the Plaintiffs life,
specifically he represented himself to be honorable, trustworthy, honest, and the fact is, the
Defendant insisted that the Plaintiff place her trust in him, which, in the circumstances,
caused the Plaintiff a measure of dependency requiring her to rely on that trust she placed in
the Defendant whom she, at all material times, considered to be a loved one.

54 The Defendant intended to cause the Plaintiff psychological harm through his calculated acts
of deception and interference with the Plaintit?s bodily integrity when he knew or ought to
have known or was willfully blind to the fact that she would not consent to sexual contact
and/or activity with him if not for his false representations. The Defendant's actions and
mlsrepresentatrons drd rn fbct cause such psychological harm, and as such they constitute the
tort of intentional infliction of mental suffering and negligence.

11
55. The psychological harm suffered by the Plaintiff has resulted in, but not limited to, her being
unable to work at ceftain times since becoming aware of the Defbndant's deception and
interference with her bodily autonomy and integrity.

56. Fudher, the Defendants threatening statements with respect to his contacts within the Hell's
Angels, with respect to his friends' capabilities of making people disappear, with respect to
his ability to abduct the Plaintiff s son with impunity, and with respect to his uttered threats
to the Plaintiff if she chose to continue to expose his actions, were intended to make the
Plaintiffapprehend serious and imminent physical harm to herself andlor her family member
in the event that she antagonrzed the Defendant. In the context in which they were made,
these statements constitute assault.

57. The Defendant's assault and battery interfered with the Plaintiffs bodily autonomy and
caused her to suffer both physical and psychological harm, the effects of which are yet to be
fully determined.

58. The Defendant's actionable wrongful conduct represents a significantly marked departure
from the ordinary standards of decent behaviour. His conduct was intentional, sufflciently
malicious and highly reprehensible such that it offends the courl's sense of decency.
Accordingly, the Plaintiff seeks and is entitled to an award of punitive damages to achieve
the objectives of punishment, deterrence, and denunciation.

59. The Plaintiff therefore claims against the Defendant as follows:

a. Past and future loss of income, to be determined;

b. Special damages, the parliculars of which will be provided at or before trial;
c. General damages for pain and suffering and psychological distress, to be determined;
d. Aggravated damages, the particulars of which shall be provided in the course of this
proceeding in accordance with the Rules of Civil Procedure;
e. Punitive damages, the particulars of which shall be provided in the course of this
proceeding in accordance with the Rules of Civil Procedure;
f. Costs; and
g. Such further and other relief as this Honourable Court may deem just.

DATED at Moncton, New Brunswick this1ffiuyof May 2016.

leresa Jones
Plaintiff
728 Boudreau Street
Dieppe, New Brunswick
ElA 6X5
Telephone: (506) 47 1 -1399
t2