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 - Defendant’s 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 - Defendant’s 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. Page 1 of 3 3. The personal Plaintiff was fully aware of her dealings with the corporate Defendant. All dealings were transparent and straight forward. Until the personal Defendant’s 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. Page 2 of 3 WHEREF ORE the Defendant submits that the Plaintiff claim be dismissed with special costs or, in the alternative, costs. Defendant?s address for service: 5262 l25A Street Surrey, BC V3X Date: 0 Apr 2016 NAROTAM SINGH DHANOA Defendant MW SURINDER KAUR Defendant BIR KANWAR SINGH DHANOA Defendant Rule 7-1 (1) ofthe Supreme Court Civil Rules states: (1) Unless all parties of record consent or the court otherwise orders, each party of record to an action must, within 35 days after the end of the pleading period, prepare a list of documents in Form 22 that lists all documents that are or have been in the party?s possession or control and that could, if available, be used by any party at trial to prove or disprove a material fact, and (ii) all other documents to which the party intends to refer at trial, and serve the list on all parties of record. Page 3 of 3