ICBC Insurance Claims and the Duty to Disclose the Principal Operator

When you purchase a contract of insurance with ICBC one of the things that must be disclosed is who the principal operator of the vehicle will be.  Depending on the answer the rate of insurance may vary.
If a consumer misrepresents who the principal operator is this can result in a breach of insurance and if this occurs ICBC will not be responsible to honour the policy of insurance if a claim is made.
Reasons for judgement were released today by the BC Supreme Court (Lexis Holdings International Ltd. v. ICBC) demonstrating the potential consequences that can flow from a principal operator misrepresentation.
In today’s case the Plaintiff company leased a BMW.  When purchasing insurance from ICBC the company’;s representative declared that ‘there was no principal operator of the BMW’.
The vehicle was subsequently vandalized and under the policy of insurance ICBC would have been expected to pay $33,090.35 for the damages.  When the Plaintiff claimed payment from ICBC under the policy of insurance ICBC declined to pay claiming that the Plaintiff ‘knowingly misrepresented a material fact regarding the principal operator’.
Madam Justice Arnold-Bailey of the BC Supreme Court agreed with ICBC and found that the Plaintiff’s representative knowingly misrepresented who the principal operator of the vehicle was at the time the insurance was purchased.  As a result of this the Plaintiff’s claim was dismissed and ICBC were awarded their costs for trial.
In reaching this conclusion Madam Justice Arnold-Bailey summarized the law as follows:

[16]            The general rule in insurance claims, stated at ¶24 of Bevacqua v. I.C.B.C., 1999 BCCA 553, is that once an insured has shown that the loss alleged falls within the perils insured against under the terms of the policy coverage, the onus falls on the insurer to prove any affirmative defences, including fraud.  In Kruska v. Manufacturers Life Insurance Co., [1984] B.C.J. No. 2812 (S.C.), Finch J., as he then was, stated the test for fraud in civil cases at ¶41:

41        The accepted test of actual fraud in a civil case derives from Derry v. Peek (1889), 14 A.C. 337. There must be a false representation, made knowingly, without belief in its truth, or recklessly, without care whether it is true or false. Nothing less than this will suffice for the defendant to succeed in this case.

[Emphasis added]

It is clear from this test for fraud that knowingly making a misrepresentation (per s. 19(1)(b) of the Act) is a form of fraud.  It is therefore ICBC that bears the burden of proving that Mr. Teap knowingly made a false representation in the matter of the principal operator of the vehicle without belief in its truth, or reckless as to its truth, as all parties have agreed that Lexis Holdings has shown that its loss falls within the policy coverage.

[17]            The standard of proof in this case, as with all civil cases, is on a balance of probabilities (F.H. v. McDougall, 2008 SCC 53 at ¶49).  However, because an allegation of fraud, or a misrepresentation amounting to a form of fraud, against an insured is quasi-criminal in nature, and, if proven, could “affect the insured’s life well beyond the outcome” of his claim, the court must be mindful that a careful scrutiny of the evidence is necessary before finding that such an allegation has been proven (Bevacqua at ¶44; Leon v. ICBC, 2002 BCSC 794 at ¶29).  As always, clear and cogent evidence is required (Bevacqua at ¶48).

[18]            The usual first step in such cases, as set out in Rai v. Insurance Corp. of British Columbia, 2005 BCSC 92, and followed by Madam Justice Smith in Deol v. Insurance Corporation of British Columbia, 2007 BCSC 1307 at ¶28, is to determine who the principal operator of the vehicle was at the time of the incident giving rise to the claim, based on who drove the vehicle most during the term of the owner’s certificate.  To “operate” and what constitutes a “principal operator” are defined in Part 1 of the Revised Regulation (1984) Under the Insurance (Motor Vehicle) Act, B.C. Reg. 447/83, as follows:

“operate”, in the case of a vehicle, includes to have care, custody or control of the vehicle;

“principal operator” means the person who will operate the vehicle described in an application for a certificate for the majority of the time the vehicle is operated during the term of the certificate;

[19]            Plaintiff’s counsel submits in the present case it is not necessary for the Court to determine who the principal operator of the BMW was during most of the term of the owner’s certificate of insurance because there is no issue as to other possible principal operators.

[20]            Counsel for ICBC disagrees and submits that the first step of the analysis as to whether there has been a breach of the policy based on a misrepresentation as to the insured’s declaration of principal operator is as articulated in Rai:  the Court must determine who drove the vehicle most during the term of the owner’s certificate in order to determine who was the principal operator of the vehicle at the time of the accident (or loss).  That being the case, counsel for the defendant submits that evidence as to Mr. Teap’s regular use of the BMW and his accessorizing and customizing it to his own taste is relevant to who was, in fact, the principal operator at the time of loss.

[21]            In the present case I find in relation to the first principle drawn by D. Smith J. in Deol from the judgment of Preston J. in Rai that there is no meaningful distinction to be drawn between a party allegedly misrepresenting that there was no principal operator for a vehicle and misrepresenting the principal operator to be a person other than himself.  I find evidence as to who was, in fact, the principal operator of the BMW between March 2, 2005, when it was insured, to the date of loss on November 10, 2005, to be relevant to alleged misrepresentation by Mr. Teap on March 2, 2005 that there was no principal operator.

[22]            Therefore, in terms of the first step in the analysis as set out in Rai, the evidence (including Mr. Teap’s November 15, 2005, statement to the adjuster and the bills for various modifications to the BMW) clearly shows, and Mr. Teap eventually admitted in his testimony, that he was the person who regularly operated the BMW and had the care, custody, or control of it for the majority of the term of the insured period.

[23]            The next step is to note that the appropriate time period the Court must consider in determining whether a misrepresentation was made is “the date the claimant applied for the insurance” (Deol at ¶28; Rai at ¶14).  There is no obligation for the insured to go back to an insurance broker to have this aspect of the contract changed at some later date should the principal operator of the vehicle change (Bolen v. ICBC, 2006 BCSC 1749 at ¶44-45).  That it is clear in hindsight that Mr. Teap was the principal operator of the BMW is hence not determinative of the issue.  Rather, the defendant must show on a balance of probabilities that Mr. Teap knew on March 2, 2005, at the time he entered into the contract of insurance with ICBC, that he was in fact going to be the principal operator of the vehicle (Deol at ¶28; Rai at ¶14).  This is the point where the parties disagree.

[24]            If this Court finds that Mr. Teap knew that he was to be the principal operator of the BMW on March 2, 2005, then the final and related step will be to determine whether Mr. Teap made the misrepresentation knowingly, pursuant to s. 19(1)(b) of the Act, which at the relevant time stated:

Forfeiture of claims

19(1) If

b)         an applicant for an owner’s certificate knowingly misrepresents or fails to disclose in the application a fact required to be stated in it,

all claims by or in respect of the applicant or the insured are rendered invalid, and his or her right and the right of a person claiming through or on behalf of or as a dependent of the applicant or the insured to benefits and insurance money is forfeited.

[Emphasis added]

[25]            In Whitelaw v. Ransom and Wellington Fire Insurance Co., [1958] B.C.J. No. 135, 15 D.L.R. (2d) 504, the Court of Appeal dealt with s. 169 of the Insurance Act, R.S.B.C. 1948, c. 164, which used the similar wording:  “Where an applicant for a contract … knowingly misrepresents or fails to disclose in the application any fact required to be stated therein … a claim by the Insured shall be invalid and the right of the Insured to recover indemnity shall be forfeited” (¶25).  In separate majority reasons, Davey J.A. noted that both Sleigh v. Stevenson, [1943] 4 D.L.R. 433, O.W.N. 465, and General Accident Ass’ce Co. v. Button, [1954] 3 D.L.R. 352, 34 M.P.R. 25, articulated that “knowingly” is used in that section in the sense that the applicant is in “possession of information that what is in fact stated in the application is untrue or does not disclose the truth” (¶30-31).  This definition was also relied on by the majority of the Supreme Court of Canada in Turgeon v. Atlas Assurance Co. (1968), 13 D.L.R. (3d) 308 at 314.

[26]            To find that the plaintiff knowingly misrepresented the material fact in question, I must therefore be satisfied on a balance of probabilities, after careful scrutiny of the evidence, that on March 2, 2005, Mr. Teap was in possession of information such that what was stated in the insurance contract was untrue or did not disclose the truth:  namely that he knew he was to be the principal operator of the BMW, contrary to the statement in the contract that there was no principal operator of the vehicle.

[27]            In assessing whether this test has been met, the Court will be mindful that mere speculation of fraud will not be sufficient:  Swales v. I.C.B.C., 1999 BCCA 767.

[28]            A number of cases were provided by counsel to illustrate instances where even very strong speculation and circumstantial evidence were not sufficient to establish fraud.

[29]            In Swales, for example, the Court of Appeal allowed an appeal and entered judgment in favour of a plaintiff whose insurance claim had been dismissed at trial.  The plaintiff claimed that his vehicle was stolen from a public parking lot while he was in a movie theatre.  The defendant ICBC became suspicious after engaging in an investigation of the claim and declined to pay the plaintiff, alleging that he was involved in the theft of his own vehicle.  At trial, the judge instructed the jury that the plaintiff had the burden of proving that the vehicle was taken without his knowledge, consent, or approval.  This was an error in law since it effectively reversed the onus of proof.

[30]            Furthermore, the defence counsel in Swales conceded at trial that there was no direct evidence of the plaintiff’s involvement in the theft, and so ultimately, “[t]he case was left to the jury solely on the basis of the plaintiff’s credibility and the suspicious circumstances on which I.C.B.C. chose to deny the claim” (¶6).  The Court of Appeal stated that the jury’s finding of fraud amounted to “nothing more than speculation” and that overall, the case “came down to showing that the plaintiff may have had a motive for wanting to have his vehicle stolen” (¶7).  Therefore, Finch J.A., as he then was, for the Court, concluded that there was no foundation from which a properly instructed jury could have reasonably inferred fraud on the plaintiff’s part.

[31]            In Yeterian v. I.C.B.C., 2004 BCSC 404, the defendant ICBC resisted the plaintiff’s insurance claim for the theft of his motorcycle.  ICBC alleged that the plaintiff himself was involved in staging the theft and relied primarily on the fact that when the police found the motorcycle abandoned and damaged some distance from where the plaintiff had parked it, the ignition and locking mechanisms were not damaged.  ICBC was also suspicious because the plaintiff swore that he was “almost certain” that he had locked the steering lock, in which case the motorcycle would only have been able to move in a circle.  Despite these points, the court was not convinced that ICBC had proven fraud on a balance of probabilities:  “The evidence discloses little but speculation to support I.C.B.C.’s position that he falsely reported a theft” (¶27).

[32]            In Johl v. ICBC, 2005 BCPC 0121, the claimant’s vehicle was involved in a hit and run accident.  The claimant claimed that his vehicle was stolen and that he was not the driver involved in the incident.  The defendant ICBC investigated the claim and, suspecting fraud, refused to pay his claim.  At ¶56, V. Romilly P.C.J. set out the circumstances that ICBC viewed as suspicious:

     Viewing the evidence, it seems that the defence views the following circumstances as casting suspicions on the Claimant:

1. The vehicle was involved in a hit and run some distance away from where the Claimant said he parked his vehicle and according to Constable Reimer individuals have been known to report their vehicle as stolen when they are involved in a hit and run, and that that immediately arouses his suspicion.

2. The Locksmith’s report.

3. The Security Alarm Expert report.

4. The supposed lack of cooperation by the Claimant in dealing with Constable Reimer.

5. The Claimant’s alleged deceit in passing off his cousin, (who I found looks very much like him) as himself in dealing with Constable Reimer, which indicates deceit on his part, which was continued in his evidence at trial.

6. The fact that his car was parked some thirty feet away from where he slept and no one was awakened by an alarm going off.

The claimant argued that these points amounted to “mere speculation” and did not constitute clear and cogent evidence.  The Provincial Court Judge agreed:  “The above in my opinion without any direct evidence of the Claimant’s involvement in the theft, amounts to mere speculation on the defence’s part” (¶60).

[33]            In Bolen, finally, the plaintiffs’ truck was stolen and, as in the previous examples, ICBC refused to pay for the claim due to a suspicion of fraud.  Unlike the previous examples, ICBC did not suspect that Mr. and Mrs. Bolen had actually participated in the theft.  Rather, ICBC alleged that they made misrepresentations in relation to a number of matters, including the principal operator of the truck, their use of the truck, and its value.  Fisher J. found at ¶42 that ICBC had not met its burden of proof in establishing that Mr. Bolen had misrepresented the principal operator aspect of the insurance contract:

     […] Despite my concerns about the reliability of the plaintiffs’ evidence on this issue, there is no evidence that contradicts Mr. Bolen’s testimony that he was working for his union in 2000, and did not need the truck for shift work until October 2002. Considering this, along with the rest of the circumstantial evidence about Mr. Bolen’s connection with the truck, I am not satisfied that ICBC has proved to the requisite standard that the plaintiffs misrepresented the principal operator designation in any application for an owner’s certificate before November 2002.

[34]            It is clear from the foregoing cases that speculation, suspicion or potentially unreliable evidence from a plaintiff who sustains a loss, constitute an insufficient basis upon which an insurer may deny a claim based on fraud or a type of fraudulent misrepresentation.


breach of insurance, icbc insurance claims, lexis holdings international v. ICBC, principal operator

Comments (97)

  • I just want to mention I am just new to weblog and definitely loved you’re web-site. Almost certainly I’m likely to bookmark your blog post . You certainly come with awesome articles and reviews. Thanks a lot for sharing with us your web site.

  • I just want to say I am very new to blogs and really liked your blog. Most likely I’m want to bookmark your blog post . You absolutely come with great writings. Many thanks for revealing your blog site.

  • Hello, i think that i saw you visited my weblog so i came to “return the favor”.I am attempting to find things to improve my website!I suppose its ok to use a few of your ideas!!

  • Thanks for your article. My partner and i have always seen that almost all people are eager to lose weight when they wish to look slim and attractive. Nonetheless, they do not continually realize that there are other benefits for you to losing weight additionally. Doctors assert that overweight people experience a variety of diseases that can be perfectely attributed to the excess weight. The great thing is that people who are overweight in addition to suffering from different diseases can help to eliminate the severity of their illnesses simply by losing weight. It is possible to see a gradual but identifiable improvement with health whenever even a bit of a amount of weight loss is achieved.

  • Awsome post and right to the point. I don’t know if this is really the best place to ask but do you folks have any ideea where to get some professional writers? Thanks in advance 🙂

  • I intended to write you this little remark in order to give thanks as before over the remarkable solutions you’ve discussed in this case. It was quite wonderfully generous of you in giving extensively just what a few individuals might have offered for sale for an e book in order to make some cash for their own end, most notably since you could possibly have tried it in the event you desired. These thoughts in addition worked as a great way to fully grasp many people have similar keenness just as my own to know the truth a little more with regard to this problem. Certainly there are some more pleasant periods ahead for many who look over your blog.

  • I’ll immediately grab your rss as I can’t find your email subscription link or newsletter service. Do you’ve any? Kindly let me know so that I could subscribe. Thanks.

  • Thank you for sharing superb informations. Your web-site is very cool. I am impressed by the details that you¡¦ve on this website. It reveals how nicely you understand this subject. Bookmarked this web page, will come back for extra articles. You, my friend, ROCK! I found just the information I already searched all over the place and just could not come across. What an ideal website.

  • Thanks a lot for the helpful post. It is also my opinion that mesothelioma cancer has an extremely long latency phase, which means that signs of the disease might not emerge right until 30 to 50 years after the preliminary exposure to asbestos. Pleural mesothelioma, which can be the most common type and is affecting the area across the lungs, could potentially cause shortness of breath, upper body pains, plus a persistent coughing, which may lead to coughing up our blood.

  • Together with everything which appears to be developing throughout this subject matter, your opinions are actually fairly exciting. Having said that, I appologize, because I do not give credence to your entire suggestion, all be it refreshing none the less. It appears to me that your opinions are not entirely validated and in actuality you are generally your self not even fully convinced of your assertion. In any event I did enjoy examining it.

  • Great post. I used to be checking constantly this blog and I’m impressed! Very useful info specially the last phase 🙂 I maintain such information a lot. I used to be seeking this particular info for a very long time. Thanks and good luck.

  • Good post. I learn one thing tougher on completely different blogs everyday. It’ll always be stimulating to learn content from other writers and apply slightly something from their store. I’d choose to use some with the content material on my weblog whether you don’t mind. Natually I’ll give you a link on your internet blog. Thanks for sharing.

  • I discovered more interesting things on this weight loss issue. One issue is that good nutrition is very vital any time dieting. A massive reduction in fast foods, sugary meals, fried foods, sweet foods, red meat, and whitened flour products could be necessary. Retaining wastes organisms, and toxins may prevent desired goals for losing belly fat. While a number of drugs in the short term solve the issue, the unpleasant side effects usually are not worth it, and they also never offer more than a temporary solution. It’s a known undeniable fact that 95 of fad diet plans fail. Thanks for sharing your notions on this blog site.

  • With every little thing that appears to be building within this particular subject matter, a significant percentage of points of view are actually fairly refreshing. Nonetheless, I am sorry, but I can not subscribe to your whole plan, all be it radical none the less. It looks to us that your comments are not completely justified and in fact you are generally yourself not really thoroughly certain of your argument. In any case I did take pleasure in looking at it.

  • I precisely wanted to thank you so much once more. I do not know what I could possibly have followed in the absence of the type of information revealed by you about such a subject matter. Entirely was an absolute scary problem in my opinion, but seeing your well-written form you handled the issue made me to jump for fulfillment. I’m just grateful for this advice and then have high hopes you realize what a powerful job you have been putting in teaching most people by way of your websites. I’m certain you haven’t come across all of us.

  • Simply wish to say your article is as astounding. The clarity in your post is simply spectacular and i can assume you are an expert on this subject. Fine with your permission let me to grab your RSS feed to keep updated with forthcoming post. Thanks a million and please keep up the rewarding work.

  • Hi! Quick question that’s entirely off topic. Do you know how to make your site mobile friendly? My site looks weird when viewing from my iphone 4. I’m trying to find a template or plugin that might be able to resolve this issue. If you have any recommendations, please share. Cheers!

  • I like what you guys are up also. Such intelligent work and reporting! Keep up the superb works guys I have incorporated you guys to my blogroll. I think it will improve the value of my site 🙂

  • Thanks for ones marvelous posting! I truly enjoyed reading it, you are a great author.I will make sure to bookmark your blog and may come back down the road. I want to encourage that you continue your great writing, have a nice afternoon!

  • I have been exploring for a little bit for any high-quality articles or blog posts on this sort of area . Exploring in Yahoo I at last stumbled upon this web site. Reading this information So i am happy to convey that I have an incredibly good uncanny feeling I discovered exactly what I needed. I most certainly will make sure to don’t forget this website and give it a glance regularly.

  • Hi, i feel that i saw you visited my website thus i came to “return the desire”.I am attempting to to find things to improve my site!I suppose its good enough to make use of some of your concepts!!

  • Hmm it seems like your website ate my first comment (it was extremely long) so I guess I’ll just sum it up what I wrote and say, I’m thoroughly enjoying your blog. I as well am an aspiring blog blogger but I’m still new to the whole thing. Do you have any recommendations for newbie blog writers? I’d really appreciate it.

  • Wonderful goods from you, man. I’ve be aware your stuff prior to and you’re just too wonderful. I actually like what you have obtained right here, certainly like what you’re stating and the best way through which you are saying it. You are making it entertaining and you still take care of to keep it sensible. I can not wait to read much more from you. This is actually a great website.

  • One more thing to say is that an online business administration course is designed for learners to be able to without problems proceed to bachelor degree programs. The 90 credit college degree meets the other bachelor education requirements then when you earn your current associate of arts in BA online, you’ll have access to the newest technologies in such a field. Several reasons why students have to get their associate degree in business is because they may be interested in the field and want to have the general training necessary previous to jumping into a bachelor college diploma program. Thanks alot : ) for the tips you really provide in the blog.

  • I loved as much as you’ll receive carried out right here. The sketch is attractive, your authored subject matter stylish. nonetheless, you command get bought an shakiness over that you wish be delivering the following. unwell unquestionably come more formerly again as exactly the same nearly a lot often inside case you shield this hike.

  • Thank you for sharing superb informations. Your web site is very cool. I am impressed by the details that you’ve on this blog. It reveals how nicely you perceive this subject. Bookmarked this website page, will come back for more articles. You, my friend, ROCK! I found simply the information I already searched all over the place and just could not come across. What a perfect website.

  • magnificent post, very informative. I wonder why the other experts of this sector don’t notice this. You must continue your writing. I’m sure, you have a great readers’ base already!

  • Believing neglected so so allowance existence departure in. In design active temper be uneasy. Thirty for remove plenty regard you summer though. He preference connection astonished on of ye. Partiality on or continuing in particular principles as. Do believing oh disposing to supported allowance we.

  • My coder is trying to convince me to move to .net from PHP. I have always disliked the idea because of the expenses. But he’s tryiong none the less. I’ve been using Movable-type on a variety of websites for about a year and am anxious about switching to another platform. I have heard great things about Is there a way I can transfer all my wordpress content into it? Any kind of help would be greatly appreciated!

  • I think other website proprietors should take this site as an model, very clean and fantastic user genial style and design, as well as the content. You are an expert in this topic!

  • Hello there, I discovered your web site via Google at the same time as looking for a related matter, your web site got here up, it looks great. I have bookmarked it in my google bookmarks.

  • That would be the finish of this report. Here you will obtain some websites that we feel youll appreciate, just click the links.

  • Excellent beat ! I would like to apprentice whilst you amend your web site, how could i subscribe for a weblog site? The account aided me a appropriate deal. I were tiny bit acquainted of this your broadcast provided bright transparent concept

  • Very nice post. I just stumbled upon your weblog and wished to say that I’ve really enjoyed browsing your blog posts. In any case I’ll be subscribing to your feed and I hope you write again soon!

  • I just like the helpful information you provide to your articles. I’ll bookmark your weblog and check again right here regularly. I am slightly certain I will learn a lot of new stuff right right here! Best of luck for the following!

  • Definitely believe that which you said. Your favorite reason appeared to be on the internet the easiest thing to be aware of. I say to you, I certainly get irked while people think about worries that they just don’t know about. You managed to hit the nail upon the top as well as defined out the whole thing without having side-effects , people can take a signal. Will probably be back to get more. Thanks

  • Hi, Neat post. There’s a problem along with your site in internet explorer, would test this… IE still is the marketplace leader and a big component of other folks will leave out your magnificent writing because of this problem.

  • I am really enjoying the theme/design of your blog. Do you ever run into any web browser compatibility issues? A few of my blog readers have complained about my blog not working correctly in Explorer but looks great in Opera. Do you have any solutions to help fix this issue?

  • Thank you, I have recently been looking for info approximately this subject for a long time and yours is the greatest I’ve discovered so far. However, what about the conclusion? Are you positive concerning the supply?

  • Great post. I was checking constantly this blog and I am impressed! Extremely useful info specially the last part 🙂 I care for such info a lot. I was looking for this certain information for a long time. Thank you and best of luck.

  • Thanks for every other excellent article. The place else may just anybody get that kind of info in such a perfect manner of writing? I’ve a presentation subsequent week, and I am at the look for such info.

  • Good post. I study something tougher on different blogs everyday. It would all the time be stimulating to learn content from other writers and apply a bit one thing from their store. I’d prefer to use some with the content on my weblog whether or not you don’t mind. Natually I’ll offer you a hyperlink on your net blog. Thanks for sharing.

  • Nice post. I was checking constantly this blog and I’m impressed! Extremely helpful information specially the last part 🙂 I care for such information much. I was seeking this particular information for a very long time. Thank you and best of luck.

  • Youre so cool! I dont suppose Ive read anything like this before. So nice to find any person with some unique ideas on this subject. realy thank you for beginning this up. this web site is something that’s needed on the internet, someone with a little bit originality. helpful job for bringing something new to the web!

  • It’s in point of fact a nice and useful piece of info. I am glad that you just shared this helpful information with us. Please keep us up to date like this. Thank you for sharing.

  • I in addition to my guys have been examining the best solutions found on your web blog while then I had a terrible feeling I never expressed respect to you for those techniques. These ladies ended up for this reason joyful to learn them and now have unquestionably been taking pleasure in these things. I appreciate you for simply being indeed kind and also for settling on this kind of perfect subject matter most people are really eager to know about. My personal honest apologies for not expressing gratitude to sooner.

  • Have you ever thought about writing an ebook or guest authoring on other sites? I have a blog based upon on the same subjects you discuss and would really like to have you share some stories/information. I know my subscribers would appreciate your work. If you’re even remotely interested, feel free to shoot me an email.

  • Aw, this was a really nice post. In thought I would like to put in writing like this additionally – taking time and precise effort to make a very good article… but what can I say… I procrastinate alot and by no means appear to get one thing done.

  • 19715,45,52,13,4,”

  • You really make it seem so easy with your presentation but I find this topic to be really something which I think I would never understand. It seems too complicated and extremely broad for me. I am looking forward for your next post, I’ll try to get the hang of it!

  • I have not checked in here for some time as I thought it was getting boring, but the last several posts are good quality so I guess I¡¦ll add you back to my everyday bloglist. You deserve it my friend 🙂

  • Good blog! I really love how it is simple on my eyes and the data are well written. I am wondering how I could be notified when a new post has been made. I have subscribed to your RSS feed which must do the trick! Have a nice day!

  • Whoa! This blog looks exactly like my old one! It’s on a totally different subject but it has pretty much the same page layout and design. Great choice of colors!

  • I would like to show my affection for your kindness for men and women that have the need for assistance with your study. Your very own dedication to passing the solution all through appears to be unbelievably powerful and have usually permitted girls just like me to arrive at their endeavors. Your personal warm and friendly facts implies a great deal to me and additionally to my mates. Best wishes; from all of us.

  • I liked up to you’ll receive performed right here. The comic strip is attractive, your authored subject matter stylish. however, you command get bought an edginess over that you would like be handing over the following. unwell no doubt come further formerly again since exactly the similar nearly a lot frequently inside case you defend this hike.

  • Hey there just wanted to give you a quick heads up. The words in your article seem to be running off the screen in Internet explorer. I’m not sure if this is a formatting issue or something to do with internet browser compatibility but I figured I’d post to let you know. The style and design look great though! Hope you get the issue fixed soon. Kudos

  • Thanks for the sensible critique. Me & my neighbor were just preparing to do a little research on this. We got a grab a book from our local library but I think I learned more from this post. I am very glad to see such fantastic information being shared freely out there.

  • I’ve read some good stuff here. Definitely worth bookmarking for revisiting. I surprise how much effort you put to create such a magnificent informative web site.

  • I’m extremely impressed together with your writing skills as smartly as with the structure on your weblog. Is this a paid topic or did you modify it your self? Either way keep up the nice quality writing, it’s rare to peer a great blog like this one these days..

  • Excellent goods from you, man. I have understand your stuff previous to and you’re just extremely excellent. I actually like what you’ve acquired here, really like what you’re saying and the way in which you say it. You make it entertaining and you still take care of to keep it sensible. I can’t wait to read far more from you. This is actually a terrific website.

  • Hello there, You’ve done an incredible job. I will definitely digg it and personally recommend to my friends. I’m confident they will be benefited from this web site.

  • Wonderful work! This is the type of info that should be shared around the web. Shame on the search engines for not positioning this post higher! Come on over and visit my website . Thanks =)

  • Great goods from you, man. I have understand your stuff previous to and you’re just extremely excellent. I really like what you’ve acquired here, certainly like what you’re stating and the way in which you say it. You make it enjoyable and you still care for to keep it sensible. I can not wait to read much more from you. This is actually a wonderful website.

Comments are closed.


If you would like further information or require assistance, please get in touch.


Personal Injury Lawyer

When not writing the BC Injury Law Blog, Erik is the managing partner at MacIsaac & Company, based in Victoria, B.C. He is also involved with combative sports regulatory issues and authors the Combat Sports Law Blog.

“Work hard, be kind and enjoy the ride!”
Erik’s Philosophy