How to Write a Counterclaim

Recipient's Name: ADEBANJO OWOEYE Your Name: BUA CEMENT Position Title: LEGAL MANAGER Company Name: BUA CEMENT Interview Date and Time: MARCH 24, 2025 08:00 AM TO 02:00 PM Interview Format: IN-PERSON Specific Questions or Requirements: PREPARE FOR A SHORT PRESENTATION AND WRITTEN TEST Additional Notes or Personal Touches: INTERVIEW MAY TAKE LONGER

can you please work with my document and keep it as close to original, only improving the strenth of the argument please; Dear honorable and esteemed judge I come to you humble Dan with the up most respect and asking for your mercy leniency understanding compassion and heart to properly review this case things are not as they seem I apologize in advance for the long read but it is necessary and understanding the back story that supports what's going on today I need to state up front that I do not have the funds for a lawyer do to home equity bags breaking their covenant to me years ago they promised me that I would have access to 50% of the equity in my home on demand that is the reason I took the decision to work with them I did not have to go this road but it seemed like a fast and easy solution that suited me as my intention was to pay the loan down completely when my inheritance is to kick in I am a single woman never having been married due to outstanding circumstances an I have no children or husband I am alone I worked diligently for 17 years at Johnston and Daniel selling luxury luxury real estate beginning in the original office lumber loyal and later moving to the bigger office at Mount Pleasant and murden under the ownership and guidance of Jamie Gardner I loved after 17 years and moved to London England to attain my masters in Fine Arts at the Christie's fine hurts in South Kensington I worked for a while at Sotheby's in London and then came back to Canada to be closer to my aging parents while in Toronto I developed a successful interior design business and was featured in many prominent pop publications like Toronto life the globe and mail city style at home Canada house and home magazine and others but most of my work remain private due to security and privacy issues with my clients my work was specialized in dealt exclusively exclusively with the top of the market mainly for the more affluent families who had acquired extraordinary financial success in their lives focusing mainly on the areas of row stone for still but additionally work in South Florida London in the UK in France my father was a gentleman from Glasgow he was a builder and developer building for very well known large companies both here and in the US he retired early at the age of 50 he was a larger than life figure admired and respected in the communities in which he moved his life revolved around the Royal Canadian Yacht Club who still Golf Club badminton racquet club osler ski club and other such clubs around Toronto and Florida his sale competitively in the America's Cup the premier cup marcinek and others my parents maintain houma north palm beach in an exclusive gated golfing community in another home on George may my mother attended McGill University and was a popular sorority girl later giving birth to three children she was a very active and committed member of the art gallery of Ontario and later at the royal Ontario museum I was brought up to be independent in that I have always been when I returned permanently from England I purchased the home on Roxboro I had a mortgage for 10 years with the Bank of Montreal everything was smooth and transparent I had no problem split so ever in the entire 10 year time working with BMO shortly after this I started to become very lethargic and I was having a hard time keeping my energy up for my very demanding business as it continued to grow and became more and more demanding eventually I was diagnosed with late stage quote late stage chronic Lyme disease bartonella in Epstein Barr I had brain fog and extremely low energy I could no longer continue to service my very special clients in the way that I had in the past 20 years I realized I had to make some changes this would entail closing my business as a result of this I would not have the funds to pay a monthly mortgage it was it was time to peer down and focus on recovering these recovering from knees debilitating illnesses the wound up with my spending three years in bed in barely able to climb the stairs to my bedroom or to drive my car it was at this point I was referred to home equity bank I felt comfortable there as an old friend from universities sister was on their board at the time and her first cousins were very good friends with my parents so this decision was taken to go this route I wanted to remain financially independent from my family in this was the means I was able to do so I discussed with my parents my plan and my dad offered at that time to pay off the RBC mortgage in full I remained firm that I wanted to remain independent and deal with my house in my way I moved forward and met with Chris willenberg from HP who I like very much he taught me through the process of how a reverse mortgage would benefit me my eliminating the monthly payments and the ability to tap in at anytime to future funds when needed up to 50% in equity of the value of my home it sounded like a great plan this was a perfect situation for me I thought Chris then referred me to a lawyer that was frequently used by home equity bank William Parker from Parker and Parker over on Mount Pleasant I reviewed the loan with bill Parker at home equity bank had drafted and I signed the document everything went smoothly and I was happy with my decision and life went on then life turned unexpectedly upside down my work my father passed away on October of 2018 it was a painful and devastating loss for me I had been his caregiver it also caused a rift between my mother and I due to unfortunate circumstances we will not discuss here but suffice it to say I suddenly became very alone in 2019 I lost my precious happy at the age of 14 it was a catastrophic loss on the heel of losing my dad I sadly had no children and she my puppy was like my child as crazy as that may sound and then unfortunately I had another loss I lost my beautiful brother leaving behind his two young children all of this happened in four very short years and it would be too much for most people to bear but this was my story in 2019 a builder purchased the other side of my semi detached home he never came to speak to me as is the protocol defined by the city and one day in the morning early myself in my 4 tenants were woken to excruciating noising noise and banging we won't knuckle through this demolition and rebuild is the entire house was taken back to the studs and rebuilt I begged them to consider the impact it was having on those of us on the other side I couldn't understand how this is being allowed by this city he was completely inhumane one day he completed the house and put up the for sale sign and quickly found a buyer the frame worker came over the following day and said boy I bet you guys are happy we're out of there now you'll have some peace famous last words problem was that the new Boyer once again he never came to speak to me as he should have per the protocol of this city and again one morning we are woken up with very loud banging the new owner began a completely new demolition from top to bottom right back to the studs as well as he did not like the framing the former builder did this time it was much worse the demolition was happening during kovid when we were all locked in the home the sound was regularly above 99 decibels and the vibrations were intense and on going I had a conversation with the owner and he said he would discuss these issues I had with his builder when he got back to me he informed me that under covert the new building codes actually allowed construction to be extended from 7:00 AM right up until 10:00 PM and then his builder plan to work on through this schedule he also informed me that it was his right and his home and he could do as he liked this man was Eastern European and perhaps not as understanding of the way Canadians go about doing things in consideration of their fellow human beings it was at this point I called a lawyer to get a cease and assist until we could come to an agreement of some sort over the noise issues that would work for everyone the lawyer insisted a cease and desist would not stop this man and that we must sue him I reluctantly went along with this plan although it would not have been my choice also around this time I learned that the owner next door was required to have a party wall permit in that party wall permit needed to have been signed by me they needed my agreement to do any work on the central shared wall. They forged my signature without my knowledge in order to attain the party wall permit I had no idea until months later when I was on a call with the city and they told me the city revoked their party wall permit immediately yet these people carried on ignoring the cities stop work order this time around they took the decision to remove each and every 140 year old heavy floor joint in the house these joy joists attach into our centre brick wall that is shared and is not insulated each and everyone of these huge floor joists needed to be manually drilled out the noise was excruciating and we had nowhere to go and it was covered then one day a jackhammer came through the third floor wall as my tenant was sleeping on his bed followed by the raccoon families and the other rodents that took to living on my third floor and crawling between the floorboards in my home that had been opened up entirely by my neighbor next door unbeknownst to me and now my home was completely open to the outside elements in the wildlife dust and no doubt asbestos was now infiltrating my home both of my four tenants had no choice but to leave their home it was absolutely impossible in excruciating living conditions I was unable to re rent for two years due to the covert lockdown and the obvious construction noise next door I lost 2 years of rent in my savings during that. I was now unable to pay any bills including the the property tax that started this problem with home equity bag I did not want to reach out to my family I wish to continue to remain independent and I did not want to give them stress at their age I also knew in the back of my mind that I had that access to over $1,000,000 in equity still from home equity bank to tap into so I called them this is when things became strange I called and spoke to someone and explained the situation I was told no worries just fill out this form and everything will be arranged for you I did this and then waited and waited I finally made a follow up call and was assured it was just to delay and to be patient again silence I call again after a few months had passed thinking they must be very busy I spoke to someone else this time he was confused as to what was happening to my application we spoke and he looked over my files and said I see no problem here I will get this approved immediately and you will hear back from me within a few days then more time goes by then weeks and still nothing I call again and I'm told oh your fall it's been turned down what in the world is going on I was verbally approved twice over the phone and waited months and months and now I'm not approved why am I not approved how is this even possible part of my arrangement with home equity bank when I slime with them that I was promised access to a further or rather up to 50% of the equity in my home and I was nowhere even close to that amount I called again and spoke to someone on the phone and explained I was under duress I had lost my tenants an my income now for two years and was involved in a difficult lawsuit over and impossible in inhumane demolition and rebuild HEB listened appeared to be understanding told me they wish to work with me announced for a copy of both the lawsuit as a backup which I provided to them and also I provided proof from the doctor that I was suffering from Lyme disease and the coat and their Co infections along with post traumatic stress disorder due to the brutal murder of my closest friend many years earlier everything was very strange seven or eight months had now passed since I first approached HEB for an extension on my loan and it never came through and I have never ever been given an explanation to this day as to why this is not OK and HEB broke a very serious commitment and promised to me when they refused to extend further funds to me not a penny and not an explanation as to why at this point things took an unpleasant turn I was getting all kinds of different answers so I reached out to Steve ranson the CEO of HEB directly for an explanation as to what was really going on this man did not even have the decency to reply to me instead I got a legal letter from dentons there law firm threatening to put my house to power cell because my taxes were not paid HEB knew exactly why my taxes were not paid I lost my income and my savings were used up in the litigation with the construction problem beside me where was HEB when I needed them why did they lie to me about further access to the funds I was promised where is the transparency so many questions on another day I called the main switchboard to try to speak to someone again and a lady named Patricia was so rude and told me I don't care if you pay your taxes or not it's too late you're going to lose your home and we don't care and then she slammed the phone down I was completely taken aback in shock with her abrupt and rude attitude so many red flags what is going on at this bank at this point I reluctantly called my mother I did not wish to involve her in such a disagreeable an unfortunate situation she became livid and called HEB and had some words with someone this time I got a call back but it was just a pleasant small talk with 0 explanation as to what was really going on just to pacify me and calm me down but nothing came without call in terms have fulfilling the promises they made to me back on the day I signed with them the whole purpose of moving to home equity bank was to eliminate any stress due to my health conditions stress exasperates my condition as my condition is neurological HEB his actually put my life in jeopardy with their deceitful tactics my home is my security and my safe place and has been for 20 some years I had two tenanted apartments to help underwrite my house costs I live very modestly by choice and I lot no longer have a car all this is due to HEB breaking their promises and commitment to me they market themselves at this as this loving warm family who wish to help seniors to live a better life the truth is the exact opposite they are they are in fact out to terrorize people and steal their homes this is what they're attempting to do with me an in my view this is active criminal activity they are predators this week I received a letter from them that the judge you read home equity banks case for power still of my house came back and stated that I have 8 days to vacate vacate my home this is completely outrageous the lawyers for gentians followed up by sending eviction notices unbeknown stomy to my four tenants telling them they too must leave the house within a days this is not only unreasonable it is criminal I am in almost 65 year old senior with no funds due to the lies and promises that were reneg Don by HEB I have a serious post traumatic stress disorder and a chronic health issues that and yet I continue to fight back my home is my safe place an I do not consent to leave it would take me 6 months just to get things packed up in order to move and I have nowhere to go nor do my tenants the landlord tenant clearly states even my tenants must be given a minimum of 60 days notice if they're being asked to move out where is this 8 day nonsense coming from it's just blows my mind yet this judge requires us all to leave with only eight days notice I am sickened and appalled at this decision it is inhumane and unconscionable I do not consent to leave my own I deserve to be treated fairly and respectfully as do my tenants I will state on the record that HEB did not fulfill their promises to further extend the 50% equity that was promised to me and this is an invalidation of any agreement we may have had there is no contract had I known that these shenanigans whatever have transpired I would never have walked through their front door they have lied to me and misled me and treated me with extreme disrespect they've broken promises and it's just extremely disappointing and stressful it is my strong belief that HEB has no contract with me as they have lied to me and broken their promises to me and to this day I have not been given any valid explanation as to why furthermore they have yet to produce the original contract that I've asked for to prove that there is in fact a valid contract I already know that answer an I hope the esteemed judge evaluates what I have shared and takes a compassionate view of where I stand into strong consideration I really wish to put an in to this harassment in criminality today thank you for your understanding I appreciate your time kindly Christy

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