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: CV-14-517197
ONTARIO
SUPERIOR COURT OF JUSTICE
B E T W E E N:
WALTER CALLAGHAN
Plaintiff
- and -
WALTER CALLAGHAN
Defendant by Counterclaim
2.
Mr. Callaghan denies the balance of facts, allegations and claims for relief,
unless otherwise admitted here.
3.
In defence to the Counterclaim, Mr. Callaghan repeats and relies on the facts
pleaded in the Statement of Claim, in addition to the further facts pleaded
here.
4.
b. persisting with this harmful conduct, even when aware of the detrimental
effects on Mr. Callaghans health;
c. aggressively advancing and accepting a complaint against Mr. Callaghan,
without even advising him of the complaint details or obtaining his
response; and
d. prohibiting Mr. Callaghan from UTGSU communications and activities, and
from the UTGSU premises itself, in knowing breach of the defendants
authority.
5.
6.
7.
8.
Mr. Callaghan specifically denies the allegations in paragraph 58, including the
allegation that Ms. Shams asked Mr. Callaghan to be more aware of his
language and then left the meeting in tears.
9.
10.
11.
12.
Mr. Callaghan pleads that the tort of harassment is not a recognized cause of
action in Ontario.
13.
Mr. Callaghan pleads that the damages sought in the counterclaim are
exaggerated, excessive and remote.
14.
TO:
WALTER CALLAGHAN
Plaintiff
-and-
ONTARIO
SUPERIOR COURT OF JUSTICE
Proceeding commenced at TORONTO