Angel Ronan Lex Scripta(TM). Precedent. 2. Madhotra v. M. WAddo et al-Court file No.: CV-2938384857281182 Please find enclosed Minutes of Settlement to be executed by all parties in furtherance of the rules with formal admissions in the pleadings and in light of usual standards of practice. I have had some response to the previous settlement offers submitted earlier this year sent reasonably in light of the file contents and the plethora of admissions by Plaintiff as evidence. But, we need agreement from all parties. Should the parties wish to continue the action to further the goals of the Court and to reduce unnecessary cost and avoid unnecessary litigation, please advise. Click here for more.

Dear Sirs;


Madhotra v. Toronto Energy Services-Court file No.: CV-28382274728382   

 2. Madhotra v. M. WAddo et al-Court file No.:  CV-2938384857281182

Please find enclosed Minutes of Settlement to be executed by all parties in furtherance of the rules with formal admissions in the pleadings and in light of usual standards of practice.  I have had some response to the previous settlement offers submitted earlier this year sent reasonably in light of the file contents and the plethora of admissions by Plaintiff as evidence. But, we need agreement from all parties.   Should the parties wish to continue the action to further the goals of the Court and to reduce unnecessary cost and avoid unnecessary litigation, please advise. There may be a principle that matters should settle in light of accepted law as digested by all parties, yet the instructions of clients as advised by counsel may lead to files being closed expediently to avoid unnecessary cost to the client. You need to seek instructions from your client.   You may wish to continue the action but without M. Waddo who owes no duty of care to the Plaintiff pursuant to the admission of the Plaintiff in the claim.    

I am expecting a response to this Settlement Offer.  Please advise of your client’s positions without any further delay. 

Thanks and Regards,       

Warren A. Lyon, Lawyer

Angel Ronan S.L.R.P.

                            Court file no: CV-19234838292'2

ONTARIO

SUPERIOR COURT OF JUSTICE

BETWEEN:

MADHOTRA

                                                           Plaintiff                                                                                                                                           

-and-

M.WADDO and CITY Of Thunderbay

                                                                     Defendants

                                                                

MINUTES OF SETTLEMENT

The parties agree to fully and finally resolve all matters between them, including, but not limited to, all disputes or differences relating to the Plaintiff’s incident with the Defendant
M. WAddo where she admits in her claim and pleading to walking across the street at night at a cross-walk with no lights in the winter in the dark at a non-functioning cross walk of such great irresponsibility for one’s own safety as an adult and as appears in her pleadings as an admission to settle the claim herein in the Ontario Civil Court Action  and the main action under CV2938384857281182 (the “Civil Action”) on the following basis:

1.    The Plaintiff and any other Defendants shall pay to the Defendant WAddo the lump sum amount of $26950.00, less mandatory statutory deductions and remittances, within ten (10) days of receipt of the properly executed Full and Final Release (referred to below) as executed by the Plaintiff and acknowledged by WAddo. Mr. WAddo will not execute his release until payment is received as instructed below;

2.    The Plaintiff shall pay to Angel Ronan S.L.R.P. the lump sum amount of $5670.00 -payable to Angel Ronan Services- on behalf of the Defendant WAddo in respect of legal fees and costs incurred by the Defendant (WAddo) in respect of the Civil Action within ten (10) days of the Plaintiff’s receipt of the properly acknowledged Full and Final Release; 

3.    The Plaintiff shall execute the Full and Final Release attached as Appendix A to the Minutes of Settlement herein and return an original of Appendix A to the Defendant within five (5) days of the date of these Minutes of Settlement;

4.    The Plaintiff shall not hereby irrevocably consent to the Defendant or any party preparing and filing a Notice of Discontinuance of this Civil Action on behalf of both parties on a without costs basis until the draft of $26950.00 and the further draft of  $5670.0 payable to the Defendant WAddo and his respective counsel as outlined above in paragraph 1 and 2 are paid by the drawee bank , and such Notice of Discontinuance, once filed on consent with copies provided to all parties, shall serve to prevent any further litigation between the parties, save for the enforcement of the terms of these Minutes of Settlement;