SUPREME COURT OF QUEENSLAND

REGISTRY:

Toowoomba

NUMBER:

42/2025

Plaintiff:

MICHAEL THOMPSON

AND

LAURA THOMPSON

[First] Defendant:

SAMIR SILVA

AND

[Second Defendant:]

ANA SILVA

CLAIM

The plaintiff claims:

Specific performance of the written contract dated 1 September 2024 for the sale of Lot 1 on Registered Plan 123456, County of Gowrie, Parish of Toowoomba, Title Reference 50123456 (the Property).
Alternatively, damages for breach of contract.
Interest pursuant to s 58 (3) of the Civil Proceedings Act 2011 (Qld).[1]
Costs.
Such further or other relief as the Court considers just.

The plaintiff makes this claim in reliance on the facts alleged in the attached Statement of Claim.

ISSUED WITH THE AUTHORITY OF THE SUPREME COURT OF QUEENSLAND

And filed in the Toowoomba Registry on 14th February 2025.

Registrar:

To the defendant[s]: TAKE NOTICE that you are being sued by the plaintiff in the Court. If you intend to dispute this claim or wish to raise any counterclaim against the plaintiff, you must within 28 days of the service upon you of this claim file a Notice of Intention to Defend in this Registry. If you do not comply with this requirement judgment may be given against you for the relief claimed and costs without further notice to you. The Notice should be in Form 6 to the Uniform Civil Procedure Rules. You must serve a sealed copy of it at the plaintiff’s address for service shown in this claim as soon as possible.

Address of Registry:

159 Hume Street

PO Box 1800

Toowoomba Qld 4350

If you assert that this Court does not have jurisdiction in this matter or assert any irregularity you must file a Conditional Notice of Intention to Defend in Form 7 under Rule 144, and apply for an order under Rule 16 within 14 days of filing that Notice.

If you object that these proceedings have not been commenced in the correct district of the Court, that objection must be included in your Notice of Intention to Defend.

PARTICULARS OF THE PLAINTIFF:

Name: Michael and Laura Thompson

Plaintiff’s residential or business address: 18 Maple Grove, Toowoomba, Qld, 4350

Plaintiff’s solicitors name: Tamara Long

and firm name: Torts & Prayers Solicitors

Solicitor’s business address: 67 Butterfly Crescent, Toowoomba, Qld, 4350.

Address for service: As Above

Dx:

Telephone: 0432 476 229

Fax: N/A

E-mail address: tamara.long@tortsandprayers.net.au

Signed:

Description: Solicitor

Dated: 12th February 2025

This Claim is to be served on: SAMIR SILVA

of: 46 Challenger Drive, Toowoomba, Qld, 4350.

And on ANA SILVA

of: 46 Challenger Drive, Toowoomba, Qld 4350.

SUPREME COURT OF QUEENSLAND

REGISTRY: Toowoomba

NUMBER: 42/2025

PLAINTIFF:

MICHAEL THOMPSON

AND

LAURA THOMPSON

[First] Defendant:

SAMIR SILVA

AND

[Second]Defendant

ANA SILVA

STATEMENT OF CLAIM

This claim in this proceeding is made in reliance on the following facts:

The plaintiffs, Michael Thompson and Laura Thompson, entered into a written contract dated 1 September 2024 for the purchase of the residential property located at 18 Maple Grove, Toowoomba, being Lot 1 on Registered Plan 123456, Title Reference 50123456 (the Property).
The defendants, Samir Silva and Ana Silva, are the registered proprietors of the Property, subject to Mortgage No. 11223344 in favour of the Commonwealth Bank of Australia.
The purchase price under the Contract was $1,850,000.
The Contract provided for payment of a deposit of $185,000 in three instalments:

(a) $60,000 payable on 1 September 2024;

(b) $60,000 payable on or before 15 November 2024; and

Special Condition 1 of the Contract provided that, upon payment of the first deposit instalment, the plaintiffs were to have access to the Property.
Special Condition 2 of the Contract provided that the defendants were permitted access to the Property prior to settlement for the purpose of removing their belongings, at reasonable times as agreed.
Settlement under the Contract was required to occur on 30 January 2025 via the online settlement platform known as Digi-Settle.
On 1 September 2024, the plaintiffs paid the first deposit instalment of $60,000.
On 3 September 2024, the plaintiffs took possession of the Property pursuant to Special Condition 1.
On 14 November 2024, the plaintiffs paid $40,000 towards the second deposit instalment.
On 16 November 2024, the first defendant contacted the plaintiffs regarding the balance of the second deposit instalment.
Later on 16 November 2024, the plaintiffs transferred the remaining $20,000 for the second deposit instalment and provided a copy of the transfer receipt.
On 17 November 2024, the first defendant acknowledged receipt of the remaining $20,000.
On 24 November 2024, the defendants attended the Property to remove personal items and discussed arrangements for collecting any future mail delivered to the Property.
On 30 November 2024, the defendants’ solicitors issued correspondence to the plaintiffs purporting to terminate the Contract and requiring the plaintiffs to vacate the Property.
On 2 December 2024, the plaintiffs’ solicitor responded asserting that the Contract remained on foot.
On 30 December 2024, the plaintiffs paid the final deposit instalment of $65,000.
On 23 January 2025, the plaintiffs’ conveyancer sent an invitation to the defendants’ solicitors to complete settlement via Digi-Settle on 30 January 2025.
On 30 January 2025, the defendants did not attend the scheduled settlement, did not provide a release of mortgage and did not provide a Form 1 Transfer.
At all material times, including on 30 January 2025, the plaintiffs were ready, willing and able to complete the Contract.
By not attending settlement and not providing the required documents to complete the transfer of title, the defendants failed to complete the Contract.
The plaintiffs claim:
(a) specific performance of the Contract dated 1 September 2024; or

(b) in the alternative, damages for breach of contract;

(d) costs; and

(e) such further or other relief as the Court considers appropriate.

Part B: Outline of Argument (Opposing Application under r 188 UCPR)

IN THE SUPREME COURT OF QUEENSLAND

REGISTRY: Toowoomba
NUMBER: 42/2025

Michael Thompson and Laura Thompson

(Plaintiffs/Respondents)

AND

Samir Silva and Ana Silva

(Defendants/Applicants)

Introduction
The Silvas seek leave under r 188 of the Uniform Civil Procedure Rules 1999 (Qld) to withdraw an admission that Samir Silva’s text of 17 November 2024 affirmed the contract and waived any right to terminate for late payment of the second deposit. The Thompsons oppose. The pleadings closed in July 2025 and the matter is trial-ready. The admission has guided the conduct of the proceeding for months. The application follows a change of solicitors, offers no new evidence or factual error, and, if granted, would disrupt efficient case management and cause unfair prejudice to the Thompsons. Considered with rr 5, 187 and 189 and the authorities below, the discretion should be exercised to refuse leave.[3]
Orders Sought
The Silvas’ application for leave to withdraw the admission should be dismissed.
Alternatively, if the Court considers granting leave, it should be strictly conditioned to remove prejudice and to preserve the current trial timetable. In Aon Risk Services Australia Ltd v Australian National University the High Court held that delay causes “an irreparable element of unfair prejudice in unnecessarily delaying proceedings,” reinforcing the need for the timely disposal of litigation. In Medina v Electro Industry Group Queensland Ltd the Supreme Court imposed conditional leave and case-flow directions to contain prejudice and maintain trial readiness, reflecting that procedural indulgence should not compromise efficiency or fairness.[4]
Materials
Claim and Statement of Claim dated 12th February 2025.
Defence dated 21st February 2025, paragraph 15 admitting affirmation and waiver.
Reply dated 17th November 2024, adopting the admission.
Affidavit of Maxine Murphy, sworn 31st October 2025 filed by New Way Legal.
Affidavit of Michael Thompson, sworn 6th November 2025, confirming pleadings closed in July 2025 and trial readiness.
Issues
Whether the Court should grant leave under r 188 to withdraw the admission that the 17 November text was an affirmation and waiver.
Whether the change of solicitors and their reassessment of legal consequences provides an adequate explanation.
Whether any genuine dispute exists about the meaning or effect of the text and subsequent conduct.
Whether delay, reliance and prejudice to the Thompsons outweigh any argument for leave.
Summary of Submissions
Rule 5 of the Uniform Civil Procedure Rules 1999 (Qld) requires that proceedings be conducted justly, quickly and at minimum cost, obliging both parties and the court to promote efficiency and fairness rather than tactical delay.[5] The withdrawal of an admission under r 188 is an exceptional remedy that is permitted only where substantive justice outweighs procedural finality.[6] The authorities demonstrate a consistent judicial refusal of leave where delay is self-induced, reliance is irreversible, and no new evidence has emerged.[7] A change of legal view, without sworn verification, mistake or fresh factual material, is insufficient and contrary to the case management philosophy embedded in r 5.[8] The Silvas’ position presents no new facts, only a revised interpretation. Allowing withdrawal would cause material prejudice to the Thompsons, who have structured their case in reliance on the existing admission.
Detailed Analysis and Application
The rules for admissions and withdrawals are governed by rr 187 to 189 read with the overarching case management duty in r 5. Those provisions promote finality and require parties to litigate efficiently. Where a party has deliberately made and adopted an admission, the courts have repeatedly refused to allow tactical retreats that would disrupt trial readiness.[9]
In Ridolfi v Rigato Farms Pty Ltd the Court of Appeal refused withdrawal of admissions made through pleading oversight, emphasising that regret is not a ground for retraction and that parties must accept the forensic consequences of their pleadings.[10] The Silvas’ change of solicitors and new legal interpretation replicate that dynamic and so attractions of Ridolfi apply here.
Medina v Electro Industry Group Queensland Ltd illustrates the practical prejudice that follows the late withdrawal of admissions.[11] The Supreme Court refused leave where the defendant offered no new evidence and the plaintiff had organised disclosure and trial strategy on the basis of those admissions.[12] The Court expressly linked its discretion to r 5 of the Uniform Civil Procedure Rules 1999 (Qld), which embodies the expectation of expedition and economy in litigation.[13] The Thompsons have acted in the same manner and would suffer analogous prejudice if withdrawal were permitted.
Hanson Construction Materials Pty Ltd v Davey confirms that withdrawal requires a real factual dispute supported by material evidence. The applicant in Hanson advanced only reinterpretation, not fresh facts, and was refused leave.[14] The 17 November text here is plain and the contemporaneous conduct of the parties supplies the factual foundation for the admission, so there is no proper dispute.
Aon Risk Services Australia Ltd v Australian National University emphasised that procedural fairness extends beyond the immediate parties to encompass the justice system as a whole. The High Court explained that late procedural reworking which imposes additional burdens on other parties and on the system should be resisted absent compelling reasons.[15] Their Honours observed that delay causes “an irreparable element of unfair prejudice” and that indulgence in such circumstances undermines the timely and efficient resolution of disputes.[16] The Court therefore cautioned that amendments and extensions of time must be consistent with the overarching objectives of fairness, economy and the integrity of the trial process.[17] The Silvas offer no such reasons here.
Applied to the facts, the Defence was settled with full knowledge of the 17 November text; the Reply confirmed its meaning. The Silvas’ late change of legal view is tactical and unsupported by new evidence. The combined effect of rr 5 and 187-189 and the authorities cited requires refusal of leave because the balance of prejudice and policy favours finality and efficient resolution.[18]
The plaintiffs have conducted disclosure, prepared witness outlines and trial submissions on the basis of the admission. Withdrawal now would necessitate re-pleading, further interlocutory steps and additional costs, causing material forensic prejudice.
Case Management Position and Conclusion
The admission should remain, the Reply should stand, and the proceeding should advance to trial on the existing pleadings with directions preserving the current timetable. Read together, rr 5 and 187-189 of the Uniform Civil Procedure Rules 1999 (Qld) impose a procedural discipline that rejects post-hoc attempts to re-litigate admitted facts and requires efficiency, fairness and finality. In Ridolfi v Rigato Farms Pty Ltd and Medina v Electro Industry Group Queensland Ltd, the Court held that a change of counsel or reinterpretation of evidence is not a sufficient basis for altering settled pleadings. Hanson Construction Materials Pty Ltd v Davey confirms that leave to withdraw an admission requires a genuine factual controversy, which is absent here. Consistent with Aon Risk Services Australia Ltd v Australian National University, timetable integrity and the efficient use of court resources must prevail. Leave under r 188 should therefore be refused and the matter directed to proceed to trial without further delay.

Part C: Critical Reflection - Artificial Intelligence and Access to Justice in Civil Litigation

Overview and central claim

Artificial intelligence is reshaping civil litigation in Queensland and beyond by simplifying procedure, accelerating document management and reducing costs, but these efficiencies are tempered by significant risks to fairness, confidentiality and professional integrity.[19] The Queensland Judicial and Non-Lawyer Guidelines warn that generative AI cannot reason, discern truth or guarantee accuracy, and that its use without independent verification risks procedural error and ethical breach.[20]The Supreme Court’s 2025 directive underscores that AI tools may “hallucinate cases, fabricate citations, and misstate law,” requiring human accountability and cross-checking before reliance.[21] Scholarship on AI and access to justice echoes this: while AI improves efficiency, affordability and inclusivity, these gains depend on transparent governance, digital literacy and sustained human oversight.[22] Collectively, the materials converge on the same principle; technology expands access only when disciplined supervision and rigorous verification accompany its use.

Queensland’s regulatory stance and its practical effect

The Queensland Guidelines for Judicial Officers confine the use of generative AI to administrative or non-decisional functions, including formatting, translation and anonymisation, while expressly prohibiting AI systems that evaluate evidence, generate reasons for judgment, or decide outcomes.[23] This limitation preserves judicial fairness, accountability and legitimacy. The companion Guidelines for Non-Lawyers caution that generative systems cannot be relied upon for correctness or completeness and that they may produce hallucinated or false citations.[24] They direct users not to upload confidential or privileged information and to verify all AI-generated outputs against authoritative legal sources.[25] Together these instruments establish a cautious and layered regulatory model, providing for limited automation at the judicial level, controlled and verified assistance for practitioners and support staff, and strict confidentiality safeguards that apply across all tiers of court use.
That regulatory posture is supported by both judicial sentiment and empirical indicators. Martinho’s 2025 survey of judges found broad acceptance of AI for clerical and retrieval functions such as document organisation and information acquisition, but strong resistance to its use in analytical or adjudicative tasks.[26] Judges expressed concern that automated reasoning can erode moral and constitutional judgment where there is no human judge in the loop.[27] In practical terms, the findings imply that courts may use AI to manage files, translate exhibits and assist with administrative workflow under direct supervision, but that any analytical or evaluative output must be reviewed and verified by humans before influencing judicial decision-making.[28]

Global experiments and the conditions for success

The British Columbia Civil Resolution Tribunal’s Solution Explorer illustrates how constrained algorithmic assistance can expand access to justice.[29] The system asks users simple diagnostic questions, provides customised legal information, and can auto-generate claim forms and self-help templates. In its 2023–24 annual report, more than 80 per cent of users reported feeling treated fairly.[30]This practical success arises from the narrow design of the tool, its transparent disclosure of purpose and limits, and its integration with a tribunal process that retains accessible human review and appeal mechanisms.
Scholarly work by Marwala and Mpedi emphasises the mechanisms through which online tribunals and AI tools reduce physical and financial barriers to justice.[31] They identify multilingual interfaces, automated document generation and predictive analytics as features that improve accessibility, particularly for marginalised or remote communities, provided ethical oversight and community participation are maintained.[32] In contrast, Singla and Gupta observe that technological efficiency creates parallel vulnerabilities, warning that algorithmic bias, data insecurity and professional de-skilling threaten fairness if governance is weak.[33] They stress that law depends on interpretive reasoning, persuasion and normative judgment, and that AI retrieval alone cannot substitute human legal skill.[34]
The combined lesson is practical. Tools such as the British Columbia Civil Resolution Tribunal’s Solution Explorer demonstrate that digital systems should be implemented only where their scope is clearly defined, their limitations are transparent to users, and accessible human assistance is available at critical decision points.[35] To achieve genuine access rather than digital exclusion, the policy environment must also invest in digital literacy, ethical governance and cybersecurity.[36] This model translates technological innovation into fair inclusion, ensuring that efficiency enhances justice rather than accelerating inequality.[37]

Failures of verification and ethical consequences

Mata v Avianca Inc demonstrates the disciplinary and systemic risks that arise when verification is neglected.[38] In that case, two attorneys filed court submissions containing fictitious AI-generated judicial opinions, quotations and citations, created by ChatGPT, and then persisted in defending their authenticity despite repeated judicial inquiries.[39] The District Court for the Southern District of New York found subjective bad faith and imposed Rule 11 sanctions, including a US$5,000 penalty and mandatory continuing legal education on technological competence.[40] The judgment framed the incident not as an anomaly but as a cautionary precedent, confirming that unverified generative output can constitute not only professional error but actionable misconduct prejudicial to the administration of justice.[41]
From a practitioner’s perspective, the implication is unambiguous. Legal professionals must implement mandatory and auditable verification protocols, avoid filing or relying on AI-generated authorities without confirming them against primary legal sources, and maintain documented records of the verification process.[42] Law firms should provide structured staff training and integrate verification checkpoints into drafting and filing workflows, while courts and regulators should formalise and reward compliance with such governance standards.[43] These measures operationalise the principle affirmed in Mata v Avianca Inc: technological competence now includes the duty to verify.[44]

Policy synthesis and practical recommendations

These materials collectively support a layered policy response. First, judicial officers should be permitted to use artificial intelligence only for non-decisional functions, such as administrative organisation, translation and anonymisation, while remaining the sole authoritative actor on questions of fact and law.[45]This preserves judicial legitimacy, maintains accountability, and limits appeal risk. Secondly, for practitioners and litigants, regulation should impose explicit verification obligations, prohibit the upload of confidential or privileged material to unvetted systems, and require auditable records of AI use and verification steps to deter careless reliance.[46] Thirdly, for public-facing access platforms such as the British Columbia Civil Resolution Tribunal’s Solution Explorer, automation should remain narrowly scoped to triage, form generation and information provision, while governments fund human review points, appeal mechanisms and digital literacy programs to ensure that technology enhances inclusion rather than deepening disadvantage.[47]
These interventions are practical and incremental. They preserve the access benefits of automation while addressing the core risks of eroded human judgment, opaque algorithmic processes, confidentiality breaches, and professional misconduct.[48] The Queensland dual-guideline framework, which divides judicial and non-judicial responsibilities, permits measured innovation while maintaining procedural integrity and public confidence in justice.[49] The British Columbia Civil Resolution Tribunal demonstrates the value of narrow and well-governed automation that improves access without displacing human oversight.[50] In contrast, Mata v Avianca Inc exposes the disciplinary consequences of unverified generative output and underlines the need for structured accountability and verification at every level of AI use.[51]

Concluding judgment

Artificial intelligence is already part of civil justice, but its value depends entirely on how it is used. The experience from Queensland, British Columbia and the United States shows that efficiency alone is not enough. Speed and automation mean little if they come at the cost of fairness, transparency or accountability. Courts and practitioners must stay in control of the process, verifying every output and keeping judgment in human hands. Well-designed systems such as the Civil Resolution Tribunal show what careful integration can achieve, while cases such as Mata v Avianca Inc warn of what happens when verification fails. The real challenge is to build technology that serves justice and ensures that innovation supports the rule of law rather than undermining it.

Civil Proceedings Act 2011 (Qld) s 58. ↑
Civil Proceedings Act 2011 (Qld) s 58. ↑
Uniform Civil Procedure Rules 1999 (Qld) rr 5(1-4);187;188;189(1-4). ↑
Aon Risk Services Australia Ltd v Australian National University (2009) 239 CLR 175 [102-106]; Medina v Electro Industry Group Queensland Ltd [2019] QSC 63, [35-85]. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) r 5; Aon Risk Services Ltd v Australian National University (2009) (n 4), [93-94]. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) r 188; Ridolfi v Rigato Farms Pty Ltd [2001] 2 Qd R 455, [19-25], [27-32]. ↑
Ridolfi v Rigato Farms Pty Ltd [2001] (n 6), [12-20]; Medina v Electro Industry Group Queensland Ltd [2019] (n 4), [46-47]. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) r 5; Aon Risk Services Ltd v Australian National University (2009) (n 4); Medina v Electro Industry Group Queensland Ltd [2019] (n 4). ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) rr 5;187-189. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) rr 5, 188; Ridolfi v Rigato Farms Pty Ltd [2001] (n 6) 455 [12-20]; 456 [18-27]; 460 [26-30]. ↑
Medina v Electro Industry Group Queensland Ltd [2019] (n 4) [46-47]. ↑
Ibid. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) rr 5, 188. ↑
Hanson Construction Materials Pty Ltd v Davey [2010] QCA 246, [16-22]. ↑
Aon Risk Services Australia Ltd v Australian National University (2009) (n 4) [102-111]. ↑
Ibid. ↑
Ibid. ↑
Uniform Civil Procedure Rules 1999 (Qld) (n 3) rr 5;187-189; Aon Risk Services Australia Ltd v Australian National University (2009) (n 4); Medina v Electro Industry Group Queensland Ltd [2019] (n 4); Ridolfi v Rigato Farms Pty Ltd [2001] (n 6); Hanson Construction Materials Pty Ltd v Davey [2010] (n 14). ↑
T Marwala and LG Mpedi, Artificial Intelligence and the Law: Artificial Intelligence and Access to Justice (Springer Nature, 2024) ch 2, esp [2.1-2.4]. ↑
The Use of Generative Artificial Intelligence (AI): Guidelines for Non-Lawyers (Queensland Courts and Tribunals, 15 September 2025) [1]–[3], [12]; The Use of Generative AI: Guidelines for Judicial Officers (Queensland Courts and Tribunals, 15 September 2025) [3-4]. ↑
21 Ibid. ↑
T Marwala and LG Mpedi (n 19). ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [23-25]. ↑
The Use of Generative Artificial Intelligence (AI): Guidelines for Non-Lawyers (n 20) [1-3]. ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [24-25]; The Use of Generative Artificial Intelligence: Guidelines for Non-Lawyers (n 20) [3-4]. ↑
Andreia Martinho, ‘Surveying Judges about Artificial Intelligence: Profession, Judicial Adjudication, and Legal Principles’ (2025) 40 AI & Society 569, 576-578. ↑
Ibid 580-582. ↑
Ibid. ↑
British Columbia Civil Resolution Tribunal, Aggregate Participant Survey Results 2023–24 (Civil Resolution Tribunal, 2024) https://civilresolutionbc.ca/solution-explorer/. ↑
Ibid. ↑
T Marwala and LG Mpedi, (n 19) ch 2, [2.1-2.4]. ↑
Ibid [2.2.4], [2.3.1-2.3.4]. ↑
Anubhav Singla and Ekta Gupta, ‘The Impact of Technology on the Legal Profession’ (2024) 10(2) International Journal of Law 112, 118-119. ↑
Ibid 119-120. ↑
British Columbia Civil Resolution Tribunal (n 29). ↑
T Marwala and LG Mpedi (n 19) ch 2, [2.3.1-2.3.3]; Anubhav Singla and Ekta Gupta, (n 33) ↑
Ibid. ↑
Mata v Avianca, Inc, 678 F Supp 3d 443 (SDNY, 2023). ↑
Ibid. ↑
Ibid. ↑
Ibid. ↑
Ibid. ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [24-25]; The Use of Generative Artificial Intelligence: Guidelines for Non-Lawyers (n 20) [3-4]. ↑
Ibid; Mata v Avianca, Inc (n 38). ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [23-25]. ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [24-25]; The Use of Generative Artificial Intelligence: Guidelines for Non-Lawyers (n 20) [3-4]. ↑
British Columbia Civil Resolution Tribunal (n 29). ↑
The Use of Generative AI: Guidelines for Judicial Officers (n 20) [24-25]; The Use of Generative Artificial Intelligence: Guidelines for Non-Lawyers (n 20) [3-4]. ↑
Ibid [23-25]; [12-17]. ↑
British Columbia Civil Resolution Tribunal (n 29) ↑
Mata v Avianca, Inc (n 38). ↑

Civil Procedure Writing Sample: Claim, Statement of Claim and Withdrawal of Admissions

STATEMENT OF CLAIM