Lawyer Negligence: Pre Judgment and Post Judgment, The Courts Of Justice Act

Statement of Claim
The Plaintiff, Sandi J. Smith claims:
$25,000,000.00 in damages for Professional Negligence;
$25,000,000.00 in damages for Fraud Intentional Misrepresentation and Breach of Contract;
$5,000,000.00 in punitive, aggravated and exemplary damages;
Special damages in the amount to be determined prior to trial;
Pre-judgment interest and post judgment interest pursuant to the Courts of Justice Act
Costs of this action on a substantial indemnity basis; and
Such further and other relief as this Honourable Court may deem just.
The Parties
The Plaintiff, Ms. Sandi J. Smith is a professional ___________ who has been employed
at the _________ and has been earning her salaries for the past ____ years. She has been in perfect physical health until the vehicular accident in the year 2008 which left her injured.
The Defendant, Cariati Law Professional Corporation spearheaded by Attorney Mario
Cariati, handled the torts case of the Plaintiff and acted as her lawyer.
The Events Giving Rise to this Action
This claim is the result of the legal malpractice committed by Attorney Mario Cariati and
his office for Breach of Contract, Fraud Intentional Misrepresentation and Professional Negligence. In addition, the defendant misused personal and confidential information provided to him in confidence and under common interest privilege to the detriment of the plaintiff.
Breach of Lawyer-Client Relationship
On several accounts, records disclosed that there has been an unreasonable failure to
respond to Plaintiff’s requests for information and non-disclosure of pertinent facts concerning her case for Tort that the Cariati Law Firm handled as a result of her car accident in the year 2008.
In addition to this complaint are the acts of dishonesty, improper representation of
conflict of interests, the neglect of the case, settling the Plaintiff’s case without her permission and failure to return legal papers upon requests.
On November 16, 2009, Plaintiff was sent to assessments without the necessary medical
records except for the incomplete copies of some medical documents from British Columbia in 2009 showing nerve damage from October 2008 until August 2009 alongside the medical documents from a Dr. Kamouna dated only at June-July 2008.
On several accounts, records disclosed that there has been an unreasonable failure to
respond to Plaintiff’s requests for information and non-disclosure of pertinent facts concerning the case for Tort that the Cariati Law Firm handled as a result of the car accident in the year 2008.
Cariati Law Firm Violates Smith’s Trust and Violated Rules of Conduct of Lawyers
In addition, the unethical and unprofessional acts committed by Attorney Cariati and his
office have caused the Plaintiff financial grief, emotional distress and sleepless nights adding ignominy to the physical suffering the Plaintiff has been experiencing after the vehicular accident.
On November 23rd, 2010 a settlement meeting is being arranged without my knowledge
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