DECEIVE DISCREDIT AND TERROR
About, Margaret Hicks' employment with AIG and events that led to her termination and claims of bad faith practices by AIG Life Insurance of Canada.
From the notes of Ron Hicks (October, 2003)

Further To: Margaret's letter dated June 24, 2002 and letter to Margaret dated and signed by Dolly Harrilal (Assistant Vice President New Business Department) dated June 27, 2002

Reference To: Margaret Hicks - Demand for compensation

Reason For Demand

Reprehensible, malicious and offensive violations of Margaret Hicks' rights under the Employment Standards Act Ontario, and the Canadian Constitution.

Employers who breach the obligation to treat employees with good faith, decency and fairness lay exposed to an independent claim for punitive damages to punish their behavior and deter their organizations and others from engaging in similar behavior. It is no longer necessary for a employee to establish that the actions or behavior of the former employer were of a tortuous nature in order to advance a claim for punitive damages. Such employees may, instead, rely upon the implied duty of the employer to act in good faith and the breach of that duty as a contractual matter.

As a employee Margaret Hicks alleges that you the employer breached its duty of good faith, decency and fairness in the decision to threaten dismissal actions and the implementation of that decision. We believe the threshold for damages resulting from your actions will be fairly high. Based on the facts and evidence that Margaret will present, it is probable that the courts will agree that the conduct and manner of threats of her dismissal are reprehensible, malicious and offensive in order to make and justify awards of punitive damages.

Margaret Hicks as a plaintiff will claim

(a) General Damages in the amount of $200,000.00 for threaten and or termination of the plaintiff's employment with the defendant. Violations and threats to violate the code of the "Employment Standards Act." (see: Margaret's letter dated June 24, 2002 and letter from Dolly Harrilal dated June 27, 2002)

Note: Dolly Harrlal telephoned Margaret while she was employed at Laurier Life Insurance (for over 9 years) a Company that is a competitor of yours and stated she wanted to hire Margaret. Margaret accepted the employment under the assurances from Ms.Harrlal that she would have job security. Since Ms. Harrilal was herself a former employee of Laurier Life and Margaret's supervisor, while she was employed by Laurier Life, Margaret trusted her and accepted employment.

(b) General Damages in the amount of $200,000.00 for negligence and the intentional infliction of nervous shock

Note: Margaret has in her possession several memos, e-mails and letters praising her for her work and cooperation from fellow employees including a document dated June 7, 2002. In this document, there are several things that Dolly Harrilal compliments Margaret on. In the letter dated June 27^th, 2002 items appear that are condemnable, malevolent and are a direct assault on her character, nature and her stature which she considers to be worthy of a high level of respect.

(c) Special damages in an amount to be proven at trial for termination by the defendant of the plaintiff's employment with the defendant regarding her current health condition "Lichen Planus." Which her Doctor states could be caused by stress. The Doctor is concerned that the medication being used to control the condition could cause severe side effects. Margaret is concerned that her ability to work in the future could be affected. She has been treated for this condition since June, 2001. In June 2001 Margaret began working an extensive amount of extra hours. Of which she has proof as Margaret was paid for the extra time. Without warning Margaret was called to a meeting and told she wouldn't be authorized for overtime pay. Yet, adequate help to perform her duties was not supplied. Margaret took the stand that she would not work without being paid. She continued to put in a solid effort to perform her duties but there was not enough time in a working day to do so. Her supervisors continued to harass her to complete her work on time but offered no constructive solutions. Margaret's termination however caused, would deny her, entitlement to health benefits that she currently has.

(d) Punitive damages in the amount of $100,000.00;

(e) Damages for mental distress in the amount of $100,000.00;

(f) Pre-judgment interest from the date of termination of the plaintiff's employment with the defendant and post-judgment interest pursuant to the Courts of Justice Act, R.S.O. 1990, c. C. 43;

(g) Costs of this action on a solicitor and client basis;

(h) Such further and other relief as to an Honourable Court may seem just.

As Margaret's husband I will be forced to pledge some shares of the company I own "Scoreboard Canada Inc." to cover the legal firms' retainer fee. I am very angry that I will have to do this to protect my wife's interests. Scoreboard Canada Inc.'s website www.scoreboard-canada.com is Canada's largest website dedicated to sports in Canada. I will publish Margaret's story with all the documents and letters we have, for all our users to view and they can see how AIG treats its employees. Perhaps, having a few hundred thousand Canadians view how you treat your employees will smarten you up. I am sure thousands of them will help us, any way they can to assist us in getting justice.

To avoid legal action and adverse publicity that could be generated by my actions I suggest you consider and out of court settlement in the amount of $900,000.00. Based on the above facts and reference to "C" Margaret will seek damages in court in excess of $2,500.000.00

If we do not here from you in a constructive manner by July 5^th, 2002 (noon) this offer to settle will expire. If it expires, I suggest you prepare yourselfs for a battle like you have never seen before. Consider this chance to settle as your final warning. I will be relentless in my persuit of justice. It may take a decision by the Supreme Court of Onrtario but, I will put all of my resources behind the legal battle to get justice. I can assure you, there will be plenty of media coverage on a daily basis. Also, for your information, the legal firm I will seek to employ already has an extensive stake in the success of Scoreboard Canada Inc. I am confident they have the extensive experience and resources that will be required to bring this matter to a successful conclusion for both Margaret and myself.

Warning:

Any attempt to obtain a restraining order to prohibit my rights to publish articles relating to this case by supplying false and misleading information to any officer of the Courts of Ontario, would be under the Criminal Code of Canada considered a criminal offence. "Possession of property obtained by crime." Any action of this nature will immediately cause me to seek a criminal investigation.


Yours Truly,

______________ ______________________

Ron Hicks  Margaret Hicks