Good afternoon your worship I am Kathy McKenty P1 licensee under the Law Society (of Upper Canada) representing

the plaintiff (plaintiffs?? include both names here) in this matter. We are here because Mr. Suer is requesting that you find in his favor for the maximum of this court, (for the injuries sustained from the motor vehicle accident, caused by the defendant, Gale Racer). On September 1, 2011 there was a serious accident involving 2 vehicles. The weather is a significant factor on how we drive on the road every day and in s.158 of the Highway Traffic Act it states that the driver of a vehicle or street car shall not follow another vehicle more closely than is reasonable, and we are stating that if the defendant was not following too closely she would not have collided with the plaintiff causing the damage or injuries. Also s.130 of the Highway Traffic Act states every person is guilty of the offence of driving carelessly who drives a vehicle on a highway without due care and attention or without reasonable consideration for other persons, ( here, you should describe what happened on the daythe events only the significant ones, likethat gale racer rear ended your client., also you cannot site law in your opening, you can state that you will rely on the highway traffic act, that based on the highway traffic act you will argue, but do not quote any sections) ( I would discuss the highway traffic act here with respect to what you will argue or what the issues are, then continue on to discuss negligence). We also intend to show the negligence of Ms. Racer while driving on the road that day. The defendant would also have you believe that she was paying full attention to the road and her surrounds and she may not have been travelling so quickly. If this was true this accident may not have been so serious, and may not had happened at all. ( here I would include that the severity of the injuries meets the requirements

under the Insurance Act and therefore you are requesting the full amount of 25, 000, ill send you my opening so you can look at the structure) Thank you, your worship I ask that I present my first witness if I may.