Commercial List Court File No 97 BK 000543 SUPERIOR COURT OF JUSTICE COMMERCIAL

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Commercial List Court File No 97 BK 000543 SUPERIOR COURT OF JUSTICE COMMERCIAL Powered By Docstoc
					                                                   Commercial List Court File No. 97-BK-000543

                             SUPERIOR COURT OF JUSTICE
                                 - COMMERCIAL LIST

                     IN THE MATTER OF CONFEDERATION LIFE
                              INSURANCE COMPANY

            AND IN THE MATTER OF THE INSURANCE COMPANIES ACT,
                           S.C. 1991, AS AMENDED

                   AND IN THE MATTER OF THE WINDING-UP ACT,
                          R.S.C. 1985, C.W-11, AS AMENDED


B E T W E E N:

                        THE ATTORNEY GENERAL OF CANADA

                                                                                Applicant

                                            - and -

                   CONFEDERATION LIFE INSURANCE COMPANY

                                                                              Respondent



              REPORT OF KPMG INC., THE LIQUIDATOR OF
              CONFEDERATION LIFE INSURANCE COMPANY

                                       MAY 1, 2000



I.            NATURE OF THE MOTION


1.            This report is filed in support of a motion by KPMG Inc., the liquidator (the

“Liquidator”) of Confederation Life Insurance Company (“Confed”), for an order approving the

Liquidator’s proposed process for the admission and disallowance of claims, including for

directions with respect to the form and manner of service of notices for the disallowance of

claims which are disputed by the Liquidator and for any appeal therefrom.
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II.            BACKGROUND

2.             On August 15, 1994 this Court ordered that Confed be wound-up pursuant to the
Winding-up Act (now the Winding-up and Restructuring Act). By further order of the same date,
the Court appointed the Superintendent of Financial Institutions (the “Superintendent”)
provisional liquidator of Confed. The Superintendent appointed KPMG Inc. as his agent to assist
in the administration of the liquidation.

3.             On September 10, 1997, this Court discharged the Superintendent as provisional
liquidator of Confed and appointed KPMG Inc. as permanent liquidator. The Superintendent
became an Inspector of the estate.

4.             On August 12, 1994, the Circuit Court for the County of Ingham, State of
Michigan (the “Michigan Court”), ordered that all of Confed’s businesses in the U.S., including
its U.S. branch, should cease as of August 12, 1994 and become known as “Confederation Life
Insurance Company (U.S.) in Rehabilitation” (“CLIC (U.S.”), an estate under the management,
direction and control of the Commissioner of Insurance for the State of Michigan as rehabilitator
(the “Rehabilitator”). By order dated October 23, 1996 and pursuant to a plan of rehabilitation
approved by such order, the Michigan Court ordered that CLIC (U.S.) be wound-up and
appointed the Rehabilitator as liquidator of CLIC (U.S.).

III.           CALL FOR CLAIMS

5.             In the Report of the Liquidator dated September 30, 1999 in support of a call for
claims (the “September 30, 1999 Report”), the Liquidator advised this Court that it had declared
a distribution percentage to policyholders of 100% of the benefits to which they are entitled
under the terms of their respective policies.

6.             In the September 30, 1999 Report, the Liquidator also advised the Court that it did
not propose to call for claims from the holders of the subordinated bonds issued by Confed (the
“Sub Debt”) as the Liquidator was of the view that the Sub Debt should be treated as
subordinated in accordance with its terms and that it was unlikely that there would be any
distributions to the holders of Sub Debt if that were the case. The Liquidator advised this Court
that it would seek a declaration in this regard from this Court before making any distribution that
could be prejudicial to the holders of the Sub Debt. On April 7, 2000, this Court gave directions
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for the giving of notice of a motion for a declaration that the Sub Debt is to be treated as
subordinated (the “Declaration Motion”). The Declaration Motion is scheduled to be heard on
May 19, 2000.

7.              By Order dated October 7, 1999, (the “October 7th Order”) this Court fixed
December 20, 1999 as the last day on or before which the following shall send in their claims:

      (a)       persons, wherever located, with debt or other claims against Confed in existence
                on August 12, 1994, whether certain or contingent, liquidated or unliquidated (the
                “Ordinary Creditors”), provided that such claims are not claims under policies of
                insurance and are not subordinated by their terms to all other indebtedness of
                Confed; and

      (b)       policyholders who held Confed policies on August 12, 1994, other than
                policyholders whose policies were issued by the United Kingdom, Cuban or
                United States branches of Confed, who assert that the claims under their policies
                have not been fully satisfied or recognized through the assumption of their
                policies by another insurer or payments made by, or in the process of being made
                by, the Liquidator (the “Additional Policyholder Claims”).

8.              In addition, the October 7th Order directed the form and manner in which the
Liquidator was to give notice of the last day fixed on or before which Ordinary Creditors and
policyholders asserting Additional Policyholder Claims must file their proofs of claim.

9.              The October 7th Order was amended by Order dated December 3, 1999 (the
“December 3rd Order”) by extending the last day on or before which a notice, substantially in
the form annexed as Schedule “B” to the October 7th Order was to be published from October
22, 1999 to November 18, 1999, and by extending the last day fixed on or before which Ordinary
Creditors and policyholders asserting Additional Policyholder Claims must file their proofs of
claim with the Liquidator from December 20, 1999 to February 15, 2000.

10.             Notices were published and proofs of claim were mailed by the Liquidator in
accordance with the October 7th Order, as amended by the December 3rd Order, as set out in the
Motion Record filed with this Court in support of the motion to amend the October 7th Order,
heard on December 3, 1999.
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11.            To date, the Liquidator has received approximately 1,100 proofs of claim in the
approximate amount of $450 million dollars, of which approximately 70 claims in the amount of
approximately $10 million were received after February 15, 2000. These amounts exclude the
claims of holders of Sub Debt, although some of holders of Sub Debt did file proofs of claim.

12.            The Liquidator is of the view that certain of the claims filed should be admitted
(the “Allowed Claims”) and that a number should be disallowed, in whole or in part (the
“Disputed Claims”).

IV.            PROPOSED PROCESS

13.            Part III of the Winding-up Act as it was in force at the commencement of
Confed’s liquidation governs the winding-up of Confed. The relevant sections are attached as
Schedule “E” hereto. They provide that:

      (a)      the Liquidator will file a statement of claimants and creditors (the “Statement”)
               with the Office of the Superintendent of Financial Institutions (“OSFI”), showing
               the amount for which each claimant and creditor is entitled to rank against the
               assets of the company (subsections 166(1) and (2));

      (b)      persons may object to the amount so shown (subsection 166(3));

      (c)      notice of the filing of the Statement is to be given by publication in the Canada
               Gazette, the official gazettes of each of the provinces and in two newspapers
               published at or nearest the head office of the Company (subsection 168(1)); and

      (d)      notice of the filing of the Statement is to be sent to each claimant or creditor,
               stating the amount for which the claimant or creditor is entitled to rank against the
               assets of the company (section 169).

14.            Pursuant to subsection 166(4), the Statement may be rectified by the Liquidator or
by the Court at any time before the completion of the liquidation.

15.            There is no precedent for the application of sections 166 through 169 to a life
insurance liquidation. In order to provide a fair and equitable process for the admission of
Allowed Claims and the disallowance of the Disputed Claims while ensuring certainty in the
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administration of the estate, the Liquidator proposes to implement a process which takes into
account both Parts I and III of the Winding-up Act, as follows:

    (a)        the Liquidator will file the Statement with OSFI showing the names of all
               claimants and creditors who have filed proofs of claim, the amounts of the
               Allowed Claims and a nil amount for the Disputed Claims. Given the declaration
               of a distribution percentage of 100% to policyholders, the Statement will include
               only those policyholders who filed Additional Policyholder Claims.              The
               Statement will also include those holders of Sub Debt who filed proofs of claim as
               well as an omnibus amount for the balance of the Sub Debt, pending the results of
               the Declaration Motion;

    (b)        the Liquidator will publish a notice of the filing of the Statement, in substantially
               the form attached hereto as Schedule “A”, in the Canada Gazette, in the official
               gazette of each province and in the national edition of The Globe and Mail and
               The National Post, as provided in subsection 168(1);

    (c)        as provided in section 169, the Liquidator will:

                      (i)     send a notice in substantially the form attached hereto as Schedule
                              “B” to those claimants or creditors with Allowed Claims after
                              approval by this Court; and

                      (ii)    send a notice of disallowance (the “Notice of Disallowance”) to
                              those policyholders, claimants and creditors having Disputed
                              Claims in substantially the form attached hereto as Schedule “C”
                              by prepaid registered mail or by fax where the only contact for the
                              claimant is a fax number; and

    (d)        the Liquidator will file a dividend sheet setting out details of the Allowed Claims
               (the “Dividend Sheet”) for approval by this Court from time to time as
               contemplated by section 85 of the Winding-up Act, prior to making any
               distributions to the holders of Allowed Claims on account thereof.



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16.            The Liquidator further proposes that policyholders, claimants or creditors with
Disputed Claims be given forty-five (45) days from the date of the Notice of Disallowance to
serve the Liquidator by prepaid ordinary mail, fax or courier with a Notice of Appeal of
Disallowance of Claim in substantially the form attached hereto as Schedule “D”, failing which
the claims of such policyholders, claimants or creditors shall be deemed to be adjusted to the
amount, if any, allowed by the Liquidator.

17.            The Liquidator will amend the Statement after completion of the appeal process
with respect to any Disputed Claim, including any court process with respect thereto, and will
seek the approval of a Dividend Sheet prior to making any further distributions.

V.             RELIEF SOUGHT

18.            The Liquidator therefore seeks an Order that:

      (a)      the Liquidator file the Statement with OSFI in accordance with section 168 of the
               Winding-up Act;

      (b)      the Liquidator publish the notice of the filing of the Statement, in substantially the
               form attached hereto as Schedule “A” as described above;

      (c)      the Liquidator send a notice in substantially the form attached hereto as Schedule
               “B” to those claimants or creditors having Allowed Claims;

      (d)      the notice advising policyholders, claimants or creditors having Disputed Claims
               that such Disputed Claims will be disallowed, be a Notice of Disallowance
               substantially in the form attached hereto as Schedule “C”;

      (e)      the Notice of Disallowance be served by prepaid registered mail or by fax on the
               policyholders, claimants or creditors having Disputed Claims at the address set
               out in the proof of claim filed by the policyholders, claimants or creditors, as the
               case may be, or, in the case where only a fax number has been provided in the
               proof of claim, to that fax number;

      (f)      any policyholders, claimants and creditors wishing to appeal the decision of the
               Liquidator serve the Liquidator with a Notice of Appeal substantially in the form
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                attached as Schedule “D” by prepaid ordinary mail, fax or courier within forty-
                five (45) days from the date of the Notice of Disallowance; and

      (g)       the Liquidator file a Dividend Sheet setting out details of the Allowed Claims for
                approval by this Court from time to time prior to making any distribution to the
                holders of Allowed Claims on account thereof.

                ALL OF WHICH IS RESPECTFULLY SUBMITTED

                                                     KPMG INC., the Liquidator of
                                                     Confederation Life Insurance Company




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                                        SCHEDULE “A”

                                                                    Court File No. 97-BK-000543

                              SUPERIOR COURT OF JUSTICE
                                  - COMMERCIAL LIST

                              IN THE MATTER OF
                    CONFEDERATION LIFE INSURANCE COMPANY

                          AND IN THE MATTER OF THE
                 INSURANCE COMPANIES ACT, S.C. 1991, AS AMENDED

                          AND IN THE MATTER OF THE
                 WINDING-UP ACT, R.S.C. 1985, C. W-11, AS AMENDED

B E T W E E N:

                         THE ATTORNEY GENERAL OF CANADA
                                                                                          Applicant

                                              - and -


                    CONFEDERATION LIFE INSURANCE COMPANY
                                                                                        Respondent



              TO THE POLICYHOLDERS, CLAIMANTS AND CREDITORS
                 OF CONFEDERATION LIFE INSURANCE COMPANY

       On August 15, 1994, a winding-up order was granted in the Ontario Court (General
Division) against Confederation Life Insurance Company, having its head office in the City of
Toronto, in the Province of Ontario.

       TAKE NOTICE THAT:

       It is intended that a Statement of Claimants and Creditors shall be filed in the Office of
the Superintendent of Financial Institutions pursuant to section 168(1) of the Winding-up and
Restructuring Act, R.S.C. not less than thirty (30) days after the date of this publication.

                                                        KPMG Inc., the Liquidator of
                                                        Confederation Life Insurance Company
                                                        800 Bay Street
                                                        8th Floor
                                                        Toronto, Ontario
                                                        M5S 3A9


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                                        SCHEDULE “B”


         [On the Letterhead of Confederation Life Insurance Company in Liquidation]


TO:             (IDENTIFY POLICYHOLDER, CREDITOR, OR CLAIMANT)

RE:             (CLAIM)


                We confirm receipt of your proof of claim dated                . The Liquidator

has reviewed your claim and will allow your claim in the amount shown on your proof of claim.


                Pursuant to the Winding-up Act (now the Winding-up and Restructuring Act), the

Liquidator is required to file a Statement of Claimants and Creditors with the Office of the

Superintendent of Financial Institutions. You will be shown as a claimant therein for the amount

claimed. You need take no further action to participate in future dividends.


                Please keep the Liquidator advised of any change of address.


                                             Yours very truly,



G26\4307218.9




                                                1
                                      SCHEDULE “C”


                                                   Commercial List Court File No. 97-BK-000543


                             SUPERIOR COURT OF JUSTICE
                                  COMMERCIAL LIST

                              IN THE MATTER OF
                    CONFEDERATION LIFE INSURANCE COMPANY

                           AND IN THE MATTER OF THE
                 INSURANCE COMPANIES ACT, S.C. 1991, AS AMENDED

                          AND IN THE MATTER OF THE
                 WINDING-UP ACT, R.S.C. 1985, C.W-11, AS AMENDED

B E T W E E N:

                       THE ATTORNEY GENERAL OF CANADA

                                                                                      Applicant

                                            - and –

                   CONFEDERATION LIFE INSURANCE COMPANY

                                                                                    Respondent



                       NOTICE OF DISALLOWANCE OF CLAIM


TO:           (IDENTIFY POLICYHOLDER, CREDITOR, OR CLAIMANT)

RE:           (CLAIM)


              TAKE NOTICE THAT as Liquidator of Confederation Life Insurance Company

(“Confed”) we have this day disallowed your claim against the estate on the following grounds:




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               AND FURTHER TAKE NOTICE THAT the Liquidator is filing the Statement
of creditors and claimants as provided in the Winding-up Act (now the Winding-up and
Restructuring Act) and that your claim will be shown thereon as nil.




               AND FURTHER TAKE NOTICE THAT if you are dissatisfied with our

decision in respect of your claim, you must serve the Liquidator by ordinary mail, fax or courier

at the address or fax number below with a Notice of Appeal, in the form attached hereto, within

forty-five (45) days of the date hereof, with support for your claim and containing the reasons for

disputing the decision of the Liquidator. Subject to the power of the Court to extend the time, no

application to revise or vary the decision in disallowing your claim will be entertained after the

expiration of forty-five (45) days from this date.


               If no Notice of Appeal is served on the Liquidator within forty-five (45) days

hereof, then this Notice of Disallowance will be deemed final and conclusive and the Liquidator

shall conduct the liquidation and distribute the assets of Confed or any part thereof among the

persons entitled thereto without regard to your claim.


               This notice is being served pursuant to the Winding-up Act and to the Order of _

dated the _day of _ 2000.
                  ,




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                DATED at the City of Toronto, this         day of            , 2000.


                                            KPMG INC., the Liquidator
                                            of Confederation Life
                                            Insurance Company
                                            800 Bay Street, 8th Floor
                                            Toronto, Ontario M5S 3A9

                                            Attention: I. George Gutfreund
                                            Fax: (416) 323-2253


                                            Per: _____________________________________
G26\4307218.9




                                               3
                                  SCHEDULE “D”

                                             Commercial List Court File No. 97-BK-000543

                          SUPERIOR COURT OF JUSTICE
                               COMMERCIAL LIST

                              IN THE MATTER OF
                    CONFEDERATION LIFE INSURANCE COMPANY

                           AND IN THE MATTER OF THE
                 INSURANCE COMPANIES ACT, S.C. 1991, AS AMENDED

                           AND IN THE MATTER OF THE
                  WINDING-UP ACT, R.S.C. 1985, C.W-11, AS AMENDED

B E T W E E N:

                      THE ATTORNEY GENERAL OF CANADA

                                                                               Applicant

                                      - and -

                  CONFEDERATION LIFE INSURANCE COMPANY

                                                                             Respondent



                 NOTICE OF APPEAL OF DISALLOWANCE OF CLAIM


TO:         KPMG INC., LIQUIDATOR OF CONFEDERATION LIFE INSURANCE
            COMPANY

FROM:       [POLICYHOLDER, CLAIMANT OR CREDITOR]
            --- ADDRESS ---

RE:         [CLAIM]




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                The policyholder, claimant or creditor herein disputes the Notice of Disallowance

of Claim dated the        day of                        , 2000.



REASONS FOR APPEAL FROM DISALLOWANCE OF CLAIM

                The policyholder, claimant or creditor disputes the Notice of Disallowance of

Claim for the reasons set out on Appendix “A”:

                [You must attach an Appendix “A” setting out the reasons for the dispute]

                In support of this appeal the policyholder, claimant or creditor submits the

evidence and documentation attached hereto as Appendix “B”.

                [You must attach evidence/documentation to support your claim as

Appendix “B”]



                DATED at the City of                 this         day of        , 2000




                                       ________________________________________________
                                       POLICYHOLDER, CLAIMANT OR CREDITOR




G26\4307218.9




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                                  SCHEDULE "E"

S. 164                                                          WINDING-UP ACT

request therefor as the Court may fix, the policyholders of the company, for
whose protection the deposit was made, shall be deemed to have refused the
reinsurance, if any, arranged by the liquidator, and, whether reinsurance has been
arranged or not, to have forfeited all right and claim to any share of the assets of
the company other than the funds or securities so deposited for their protection
outside Canada. R.S.C., c. W-10, s. 165.

        165. Transfer to British or foreign liquidator. — Where a foreign
company the insurance of risks in Canada by which has been approved by order
of the Superintendent under Part XIII of the Insurance Companies Act, is in
liquidation in the country in which its head office is situated, the Treasury Board
may, if it deems it advisable and in the interests of the policyholders in Canada,
authorize the liquidator, subject to the approval of the court, to transfer the assets
in Canada of the company to the liquidator in that country. R.S.C., c. W-10, s.
166; 1991, c. 47, s. 751.

        166. (1) Liquidator to prepare statement of claimants and creditors.
— The liquidator shall, without the filing of any claim, notice or evidence or the
taking of any action by any person, prepare a statement of all the persons
appearing by the books and records of the company to be creditors of the
company or to be claimants under any policy including any matured, valued or
cancelled policy, taking cognizance in that connection of all claims that have
arisen in accordance with the terms of the policies of which he has notice.

        (2) Collocation. — The statement described in subsection (1) shall show
the amount, determined as provided in section 161 in respect of policyholders, for
which each person is to rank as a claimant or a creditor and every such person
shall be collocated and ranked as, and is entitled to the right of, a claimant or a
creditor for the amount so ascertained by the liquidator, without riling any claim,
notice or evidence, or taking any action.

       (3) Objections. — Any collocation made pursuant to subsection (2) may
be contested by any person interested, and any person who is not collocated, or
who is dissatisfied with the amount for which he is collocated, may file his own
claim.

        (4) Amendment of statement. — The liquidator or the court may rectify
any statement prepared under subsection (1) on account of omissions or errors
therein notified to the liquidator or discovered by him at any time before the
completion of the liquidation, and only the claims appearing in the statement or
amended statement shall be regarded in the distribution of the assets. R.S.C., c.
W-10, s. 167.

        167. Right of action not debarred. — Where the assets are not sufficient
to cover in full all claims appearing in the statement or amended statement
described in section 166, the policyholders are not barred from any recourse they
have, either in law or equity, against the company issuing the policy or against
any shareholder or director thereof, except in respect of the share, if any, received
in the distribution of those assets. R.S.C., c. W-10, s. 168.

        168. (1) Copy of statement filed in Office of the Superintendent of
Financial Institutions. — A copy of the statement mentioned in section 167,
certified by the
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PART III - INSURANCE COMPANIES                                                  S. 172

liquidator, shall be filed in the Office of the Superintendent of Financial
Institutions, after not less than thirty days notice of the liquidator's intention to do
so has been given by the liquidator by notice in the Canada Gazette and in the
official gazette of each province, and in two newspapers issued at or nearest the
place where the head office of the company or the chief agency of the company in
Canada, as the case may be, is situated.

        (2) When policyholder to rank as creditor. — Any claim that has arisen
under the terms of a policy of which notice is received by the liquidator after the
date of the riling of a statement mentioned in section 167 shall rank on the assets
only for the value entered in the statement, unless the assets are sufficient to pay
all claimants in full, and in that case, the policyholder shall rank as a creditor for
the balance of his claim. R.S.C., c. W-10, s. 169; 1985, c. 19 (3rd Supp.), s. 46.

        169. Notice of filing. — The liquidator shall forthwith send by prepaid
mail a notice of the filing of the statement under subsection 168(1) to each
claimant or creditor named in the statement, addressed to the latest address on
record with the company, stating therein the amount for which the creditor or
claimant is entitled to rank against the assets of the company. R.S.C., c. W-10, s.
170.

        170. Report to the Superintendent. — Where the company is a
company, society, foreign company or provincial company within the meaning of
the Insurance Companies Act, the liquidator shall report to the Superintendent
once in every six months, or more often, as the Superintendent may require, on
the condition of the affairs of the company, with such particulars as the
Superintendent may require. R.S.C., c. 1970, c. W-10, s. 171; 1991. c. 47, s. 752.

        171. Publication of notice of proceedings. — Publication in the Canada
Gazette, in the official gazette of each province and in two newspapers published
at or nearest the place where the head office of the company or chief agency of
the company in Canada, as the case may be, is situated, of notice of any
proceedings of which, under this Act, creditors should be notified, is sufficient
notice to holders of policies in respect of which no notice of claim has been
received. R.S.C., c. W-10, s. 172.

        172. Priority of certain claims. — Nothing in this Part prejudices or
affects the priority of any mortgage. lien or charge on the property of the
company. R.S.C., c. W-10, s. 173.




                                          347
       CONFEDERATION LIFE INSURANCE COMPANY, IN LIQUIDATION
                    WEBSITE LEGAL DISCLAIMER


This website (the "Site") contains legal documents pertaining to the windup of Confederation Life
Insurance Company. This Site is presented as a public service for informational purposes only by
Confederation Life Insurance Company by its Liquidator, KPMG Inc. (the "Liquidator"). KPMG LLP is not
the Liquidator and has no responsibility for the contents of this Site. WARNING: Transmissions to the Site
are not protected and no confidentiality will be maintained with respect thereto. Transmissions to the Site
are made at the sender's risk.

This Site is not an official reporter, and the Liquidator does not guarantee that all information is error free,
complete, or accurate. The Site does not purport to provide complete records of all litigation and legal
documentation pertaining to Confederation Life Insurance Company, in Liquidation. The Site contains no
legal advice and nothing herein shall be taken, implied or construed as an offer to provide, or a provision
of, legal advice. The Liquidator may change, modify, suspend, or discontinue the Site at any time without
notice.

Based on the fundamental universal condition of the electronic communication process, the Liquidator
does not guarantee or warrant the Site will be uninterrupted, without delay, error-free, omission-free, or
free of viruses. Therefore, the information is provided "as is" without warranties of any kind, express or
implied, including accuracy, timeliness and completeness. In no event shall the Liquidator, its employees,
agents, consultants, legal counsel, contractors, or affiliates be liable for any direct, indirect, incidental,
special, exemplary, punitive, consequential or other damages whatsoever (including, but not limited to,
liability for loss of use, data or profits), without regard to the form of any action, including but not limited to
contract, negligence or other tortious actions, arising out of or in connection with the Site, any content on
or accessed by use of the Site, or any copying, display or other use hereof.

External links are provided on the Site as aids to help you identify and locate other sources of information
that may be of interest, and are not intended to state or imply that the Liquidator endorses, sponsors, is
affiliated or associated with or is legally authorized to use any trade name, registered trademark, logo,
legal or official seal, or copyrighted symbol that may be reflected in the links. In no event shall the
Liquidator, its employees, agents, consultants, legal counsel, contractors, or affiliates accept responsibility
for the accuracy of the link, the accuracy or completeness of any information obtained through any link.
The Liquidator further warns against reliance on any information contained therein and further disclaims
any knowledge or information as to the truth or accuracy of the information contained therein.

The Site is controlled by the Liquidator from its offices within the Province of Ontario, Canada. By
accessing the Site, you and the Liquidator agree that all matters relating to access to, or use of the Site
shall be governed by the laws of the Province of Ontario and the laws of Canada applicable therein,
without regard to the conflicts of laws principals thereof. You and the Liquidator also agree and hereby
submit to the exclusive personal jurisdiction and venue of the courts of the Province of Ontario with
respect to such matters.

				
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Description: Disputed Life Insurance Claim document sample