Peter Simm Helps Fellow Ontario Lawyers Resolve Problematic Pleadings


As Justice Epstein has observed: “The importance of pleadings cannot be overemphasized.”

In motions or Rule 14.05 applications, the specific content of affidavits may likewise take on critical importance as the sole source of evidence.

Peter A. Simm has won cases in 18 areas of law, and has substantial experience in successfully preparing all kinds of civil pleadings and other court documents, including:

•  Statements of Claim

•  Statements of Defence and Counterclaim

•  Replies

•  Crossclaims

•  Third Party Claims

•  Notices of Application

•  Notices of Application for Judicial Review

•  Notices of Motion

•  Notices of Appeal

•  Affidavits

Careful drafting avoids potential pitfalls, while orienting the court towards the desired goal-line.

Simm can collaborate with counsel of record in drafting key documents. Where documents have already been drafted, he can review them and, if appropriate, suggest specific amendments. Simm’s breadth of legal knowledge has enabled him to suggest viable causes of action (or viable defences) beyond those initially raised by commissioning counsel.

When reviewing opposing pleadings, Simm has demonstrated a keen eye for spotting particular paragraphs or even entire causes of action or defences that are vulnerable to being struck. Conversely, pleadings that he has drafted have never had any portion struck.