Memorandum. To:. Paralegal student-at-law From:. Tom Sm

Added on - 20 Sep 2019

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MemorandumTo:Paralegal student-at-lawFrom:Tom SmithDate:November 7, 2016Re:Muriel Doiron v. Jackson Pool – Affidavit PreparationOur File No: CIV-16-2558Prepare an Affidavit regarding the below case issues. Our client, Muriel Doiron will attend ourofficeNovember 11, 2016 at 11amto swear this Affidavit before you. This Affidavit will beused in support of discussions at a case settlement conference scheduled forNovember 16, 2016.1. At the Superior Court of Justice, Small Claims Court (Toronto), court file no: SC-16-198745-00, our Plaintiff client, Muriel Doiron, has an ongoing lawsuit against theDefendant, Jackson Pool.2. On May 15, 2016, Muriel Doiron loaned Jackson Pool one of her $3000 cedar-striprental canoes for his use during the summer season, starting on June 1, 2016. Theconsideration for this loan was Jackson Pool’s agreement to reseal and refinish the canoeand return it to her no later than September 1, 2016. Muriel and Jackson signed theattached Canoe Loan Agreement confirming the terms of this arrangement;3. On September 1, 2016, Jackson Pool failed to return the canoe to Muriel Doiron;4. Muriel sent Jackson two registered letters demanding the return of her canoe. Theseregistered letters were sent to Jackson on each of September 15, October 1, 2016,respectively. See attached registered demand letters.5. Up to and including the date that Muriel is swearing her Affidavit, she has not yetreceived a return of the canoe and wants it returned by Jackson.
September 20, 2019MUSKOKA CANOEOUTFITTERS13 Taynor Road, Bracebridge, Ontario P1L 3S6(705) 555-1212CANOE LOAN AGREEMENTBetween:Muriel Doiron (“Muriel”)andJackson Pool (“Jackson”)By placement of our signatures below we each agree as follows concerning the loanof a canoe by Muriel to Jackson:1.Jackson wishes to borrow for his personal use a used 16-foot cedar strip canoe for fromJune 1, 2016 to August 31, 2016, inclusive;2.Muriel owns a used 3-year-old, 16-foot cedar strip canoe and that needs normalrepair/maintenance work done to it of resealing and refinishing caused by normal wearand tear (the “CANOE”);3.In consideration of Muriel lending Jackson the CANOE for his personal use from June 1,2016 to August 31, 2016, inclusive, Jackson agrees at his sole expense to personallyperform the normal repair/maintenance resealing and refinishing of the CANOE, to thesatisfaction of Muriel, and return the canoe to Muriel by no later than 4pm on September1, 2016;4.If Jackson fails to return the CANOE in accordance with this agreement, he agrees to paythe replacement cost of the canoe to Muriel;2
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