Motion to Strike Paragraph 4 from Statement of Defence


1. An Order striking paragraph 4 from the Defendant’s Statement of Defence.

2. An Order compelling the Defendant to deliver an Amended Defence, without paragraph 4, forthwith;

4. Such further and other Order this Honourable Court deems just.


1. Rules 12.02(1)(a) and 15 of the Rules of Small Claims Court

2. The President and CEO of Rogers Communications Inc., Ted Rogers, personally and publicly acknowledged that the behaviour of Rogers Wireless in the matters relating to my Rogers Wireless account (4-6020-6717) (“the Account”) was “inexcuseable”.

3. The Vice President of Rogers Communications, Jan Innes, publicly acknowledged on national television that Rogers Wireless Inc. did not follow its “normal procedure” in my case. She indicated, on the behalf of Rogers Wireless Inc, that the corporation was very sorry that I had been subjected to the experiences that I endured relating to the Account.

4. Mr. Rogers and the executive members of Rogers Wireless Inc have unreservedly acknowledged full responsibility for the debacle associated with the Account.


5. Such further and other grounds that the Plaintiff may advise and this Honourable Court may permit.

The following will be relied on at the hearing of the motion:

6. The Affidavit of Susan Drummond with Exhibits


7. Such further and other material that the Plaintiff may advise and this Honourable Court may permit.