$17.5 MILLION LAWSUIT AGAINST AMHERST CHRYSLER 1999 LTD., JESSICA THERESA AMIRAULT (JESSICA ALLEN), MICHAEL RODNEY ALLEN (MIKE ALLEN), JOHN RICHARD AND SARA BEERS SPENCER

I am pursuing a civil lawsuit seeking approximately CAD $17.5 million in damages against Amherst Chrysler 1999 Ltd. and the individual defendants named above.

My lawsuit arises from what I allege were false, inaccurate, missing, and improperly handled records connected with my 2018 Jeep Wrangler transaction and the identification-verification process associated with the financing.

These are allegations made in civil litigation. The defendants are entitled to dispute them, and liability and damages will ultimately be determined through evidence and the court process.

DEFENDANTS BEING SUED

The defendants I identify in this civil lawsuit are:

• Amherst Chrysler 1999 Ltd.

• Jessica Theresa Amirault, also known as Jessica Allen

• Michael Rodney Allen, also known as Mike Allen

• John Richard

• Sara Beers Spencer

IMPORTANT WITNESSES — NOT DEFENDANTS

Wendy Allen-Helpard is not being sued. She is identified as an important witness.

Scott Lockhart is not being sued. He is identified as an important witness.

Their roles are different from those of the defendants, and I am not seeking damages against either Wendy Allen-Helpard or Scott Lockhart.

WHY I AM SUING

At the centre of my lawsuit is the Scotiabank Customer Identification Verification Form prepared in connection with my purchase and financing of a 2018 Jeep Wrangler.

I allege that the identification information recorded on that document was inaccurate.

My position is that information associated with my Nova Scotia Identification Card was described on the form as though it came from a Nova Scotia driver’s licence.

I maintain that my actual Nova Scotia driver’s licence was not issued until September 4, 2018, after the vehicle transaction.

That difference is extremely important to my case.

I further maintain that copies of my identification were transmitted to Amherst Chrysler electronically in connection with the transaction.

This leads to one of the central questions in my lawsuit:

WHERE ARE THE ORIGINAL EMAILS AND WHERE ARE THE COPIES OF THE IDENTIFICATION THAT THE DEALERSHIP RECEIVED?

This involved the financing and delivery of an approximately $50,000 Jeep.

My position is straightforward: identification would have been required as part of a significant financed vehicle transaction. If Amherst Chrysler received copies of my identification, the complete record should establish exactly what identification was received and relied upon.

I therefore seek disclosure of the original emails, attachments, customer records, financing records, identification copies, internal dealership communications, electronic records, and any archived or backup material that may still exist.

AMHERST CHRYSLER 1999 LTD.

I am suing Amherst Chrysler 1999 Ltd. because the disputed vehicle transaction occurred through the dealership and because the records, employees, financing procedures, identification procedures, and communications at issue arose from dealership operations.

The lawsuit seeks to determine the dealership's responsibility for:

• receiving and verifying customer identification;

• preparing and maintaining financing documentation;

• maintaining the customer transaction file;

• retaining copies of identification;

• preserving emails and attachments;

• communicating information to Scotiabank;

• communicating information to investigators;

• preserving relevant evidence after a dispute arose; and

• supervising employees involved in the transaction.

A central issue is whether the dealership can account for the original identification records and communications surrounding a financed vehicle transaction of approximately $50,000.

JESSICA THERESA AMIRAULT / JESSICA ALLEN

Jessica Theresa Amirault, also known as Jessica Allen, was involved in the transaction as a Business Manager.

I allege that she was directly involved with the disputed Scotiabank Customer Identification Verification Form.

I maintain that identification documentation had been provided electronically in connection with the transaction.

The lawsuit therefore raises important questions concerning:

What identification did Jessica Allen actually receive?

What documents were attached to the emails?

What identification did she review?

What information did she enter or certify on the Scotiabank form?

Why does the disputed form describe the identification in the manner it does?

Where are the original identification copies?

Where are the relevant emails and attachments?

Were those communications retained, archived, deleted, or otherwise lost?

I seek documentary disclosure and examination under oath to determine the answers.

MICHAEL RODNEY ALLEN / MIKE ALLEN

Michael Rodney Allen, also known as Mike Allen, is identified in connection with his senior management or ownership role at the dealership.

I seek evidence concerning what management knew about the original transaction and what happened after questions arose concerning the customer's identification and financing records.

His role is relevant to issues including dealership procedures, employee supervision, record retention, internal investigation, preservation of evidence, and the dealership's later communications concerning the transaction.

The lawsuit seeks to determine his actual knowledge and responsibility based on evidence rather than assumption.

JOHN RICHARD

John Richard is identified in connection with his position as General Manager.

His management role makes a number of issues potentially relevant, including:

• dealership record-retention practices;

• employee responsibilities;

• access to customer files;

• email preservation;

• identification procedures;

• financing procedures;

• management knowledge of the dispute; and

• efforts made to locate or preserve the original records.

I seek disclosure concerning what John Richard knew, when he knew it, and what actions were taken once the transaction became the subject of a serious dispute.

SARA BEERS SPENCER

I identify Sara Beers Spencer because of her finance-related involvement with the transaction.

Her evidence may be relevant to:

• financing documentation;

• customer records;

• identification documentation;

• refund matters;

• internal communications;

• the dealership's customer file; and

• the handling and preservation of transaction records.

I seek disclosure concerning what documents she created, received, reviewed, maintained, or had access to and what she knows about the transaction.

WENDY ALLEN-HELPARD — IMPORTANT WITNESS, NOT A DEFENDANT

Wendy Allen-Helpard is not being sued.

I identify her as an important witness because of her role as Controller and because I maintain that she may have knowledge concerning the dealership's electronic records, emails, identification copies, accounting records, and document-retention practices.

Her evidence is particularly important to determining what happened to the records I say were provided to the dealership.

The questions I want answered include:

Did the dealership receive copies of my identification by email?

Where were those copies stored?

Were the attachments placed in the customer or financing file?

Where are those copies today?

Where are the corresponding emails?

Were emails or attachments deleted?

If records were deleted or became unavailable, when did that occur?

Who had custody or control of those records?

Were backup copies available?

Were relevant records preserved once legal or police proceedings became foreseeable?

I maintain that Wendy Allen-Helpard may possess important evidence concerning these issues. I want that evidence obtained through proper disclosure and testimony.

SCOTT LOCKHART — IMPORTANT WITNESS, NOT A DEFENDANT

Scott Lockhart is not being sued.

He is an important witness because he was a salesperson connected with Amherst Chrysler during the relevant transaction.

His evidence may assist in establishing:

• how the original transaction occurred;

• how identification documents were provided;

• whether documents were transmitted electronically;

• how quickly the financing was approved; 5 Minutes

• who was involved in processing the purchase; and

• whether he was ever contacted by police or investigators concerning a transaction in which he had direct involvement.

I am not seeking damages against Scott Lockhart.

I want his evidence preserved and heard because it may help establish what actually happened in 2018.

THE CENTRAL QUESTION: WHERE ARE THE EMAILS AND IDENTIFICATION COPIES?

This is one of the most important evidentiary issues in my lawsuit.

The dealership financed and delivered an approximately $50,000 Jeep.

My position is that identification was supplied to the dealership.

If that is correct, there should be a documentary trail showing what was received and how it was used.

I want the evidence to answer:

What identification was actually received?

Who received it?

On what date was it received?

To which email address was it sent?

Who opened the email?

Who examined the attachments?

Were the identification documents printed?

Were electronic copies retained?

Were they placed in the financing or customer file?

What identification was used to complete the Scotiabank verification form?

Were those documents available when Scotiabank later investigated the transaction?

Were they available when police became involved?

Why are the original copies not among the records presently available to me?

Why are relevant emails and attachments missing?

Those are factual questions that should be answered through the original evidence.

WHY THE ORIGINAL DOCUMENTS MATTER

The original identification documents and emails can potentially establish exactly what information Amherst Chrysler possessed when the financing was processed.

That evidence can then be compared with the information recorded on the disputed Scotiabank form.

I therefore seek complete production of relevant material, including:

• the original Scotiabank Customer Identification Verification Form;

• copies of every identification document received;

• emails transmitting identification;

• attachments to those emails;

• dealership email-server records where available;

• archived and backup records where available;

• financing and credit documentation;

• customer-management-system records;

• internal notes;

• cancellation documentation;

• refund records;

• internal employee communications;

• communications with Scotiabank;

• communications with police or investigators;

• records relating to the repossession and disposition of the Jeep; and

• any other contemporaneous documents connected with the transaction.

THE CONSEQUENCES I ALLEGE

I allege that disputed information arising from this transaction later became part of a much larger sequence of events that caused severe consequences.

Those alleged consequences include:

• a police investigation;

• a false-pretence prosecution;

• an arrest warrant;

• prolonged legal proceedings;

• passport-related consequences;

• substantial legal and administrative expenses;

• damage to my reputation;

• career and income losses;

• lost opportunities;

• serious disruption to my family; and

• other financial and personal damages.

I dispute the underlying allegations made against me and maintain that the original dealership records are essential to establishing what actually occurred.

THE $17.5 MILLION CIVIL CLAIM

I am seeking approximately CAD $17.5 million in damages in civil litigation for losses and consequences I allege were caused or contributed to by the conduct at issue.

The damages claimed include alleged financial losses, career consequences, reputational harm, legal expenses, family impacts, lost opportunities, and other compensable damages that I intend to establish through evidence.

The $17.5 million figure is an amount being claimed in litigation. It is not a judgment already awarded by a court.

The defendants have the right to answer and contest the allegations.

The court will ultimately determine what occurred, whether any defendant is legally liable, and what damages, if any, should be awarded.

WHAT I WANT

I want the complete documentary record.

I want the original emails.

I want the original identification copies.

I want the financing records.

I want the relevant witnesses questioned under oath.

I want to know exactly what identification Amherst Chrysler received, who received it, what was recorded, what was preserved, what disappeared, and why important records are now missing.

Most importantly, I want responsibility determined from the evidence.

That is what this $17.5 million civil lawsuit against Amherst Chrysler 1999 Ltd. and the named defendants is about.