### Statement of Claim - Draft
**Court File No.: [Insert File Number]**
**Court Location: [Insert Location]**
**BETWEEN:**
**[Name of Lead Plaintiff(s)]**, on behalf of all Class Members
**Plaintiff(s)**
AND
**[Suncor Energy Inc.]**
**[Imperial Oil Limited]**
**[Canadian Natural Resources Limited]**
**[Husky Energy Inc.]**
**[Cenovus Energy Inc.]**
**[Encana Corporation (Ovintiv Inc.)]**
**[TC Energy Corporation]**
**[Pembina Pipeline Corporation]**
**[Enbridge Inc.]**
**[Teck Resources Limited]**, etc.
**Defendant(s)**
---
### Nature of the Action
1. This is a class action on behalf of all individuals and entities in Canada adversely affected by the defendants' actions and omissions that have contributed to environmental degradation and climate change.
### Parties
2. **Plaintiff(s):**
a. [Name], residing at [Address], represents the class members affected by the defendants' actions.
b. Class members include all residents, businesses, and entities in Canada suffering from environmental and economic damages caused by the defendants.
3. **Defendant(s):**
a. **Suncor Energy Inc.**, a corporation with its head office located at [Address].
b. **Imperial Oil Limited**, a corporation with its head office located at [Address].
c. **Canadian Natural Resources Limited**, a corporation with its head office located at [Address].
d. **Husky Energy Inc.**, a corporation with its head office located at [Address].
e. **Cenovus Energy Inc.**, a corporation with its head office located at [Address].
f. **Encana Corporation (Ovintiv Inc.)**, a corporation with its head office located at [Address].
g. **TC Energy Corporation**, a corporation with its head office located at [Address].
h. **Pembina Pipeline Corporation**, a corporation with its head office located at [Address].
i. **Enbridge Inc.**, a corporation with its head office located at [Address].
j. **Teck Resources Limited**, a corporation with its head office located at [Address].
k. [Include any other relevant oil companies].
### Facts
4. The defendants are major oil companies engaged in the extraction, production, refining, and sale of fossil fuels.
5. The defendants have long known about the environmental impacts of fossil fuel consumption, including climate change and pollution.
6. Despite this knowledge, the defendants have continued their activities without adequate measures to mitigate environmental harm.
7. The defendants have also engaged in misleading marketing practices, downplaying the risks associated with fossil fuel consumption.
### Legal Claims
8. The defendants have breached their duty of care to the plaintiffs and class members by:
a. Failing to take reasonable steps to prevent environmental damage.
b. Misleading the public about the environmental impact of their products.
c. Contributing to climate change and pollution, causing harm to health, property, and livelihoods.
9. The defendants' actions constitute:
a. Negligence
b. Public nuisance
c. Breach of statutory duty (reference specific environmental laws and regulations)
d. Unjust enrichment
### Damages
10. The plaintiffs and class members have suffered and continue to suffer:
a. Environmental damage, including but not limited to pollution of air, water, and soil.
b. Economic losses, including but not limited to property damage, increased living costs, and loss of income.
c. Health impacts due to exposure to pollutants and climate change effects.
### Relief Sought
11. The plaintiffs, on behalf of the class members, seek the following relief:
a. General and special damages for the harm suffered.
b. An order requiring the defendants to pay for the costs of environmental remediation.
c. An injunction preventing the defendants from continuing harmful practices.
d. Punitive damages to deter similar future conduct.
e. Any other relief that this Honourable Court deems just.
### Certification
12. The plaintiffs seek an order certifying this action as a class proceeding pursuant to the Class Proceedings Act, 1992, S.O. 1992, c. 6.
### Trial by Jury
13. The plaintiffs request a trial by jury.
---
**Dated:** [Date]
**[Plaintiff's Lawyer Name]**
**[Law Firm Name]**
**[Address]**
**[Contact Information]**
**Court File No.: [Insert File Number]**
**Court Location: [Insert Location]**
**BETWEEN:**
**[Name of Lead Plaintiff(s)]**, on behalf of all Class Members
**Plaintiff(s)**
AND
**[Suncor Energy Inc.]**
**[Imperial Oil Limited]**
**[Canadian Natural Resources Limited]**
**[Husky Energy Inc.]**
**[Cenovus Energy Inc.]**
**[Encana Corporation (Ovintiv Inc.)]**
**[TC Energy Corporation]**
**[Pembina Pipeline Corporation]**
**[Enbridge Inc.]**
**[Teck Resources Limited]**, etc.
**Defendant(s)**
---
### Nature of the Action
1. This is a class action on behalf of all individuals and entities in Canada adversely affected by the defendants' actions and omissions that have contributed to environmental degradation and climate change.
### Parties
2. **Plaintiff(s):**
a. [Name], residing at [Address], represents the class members affected by the defendants' actions.
b. Class members include all residents, businesses, and entities in Canada suffering from environmental and economic damages caused by the defendants.
3. **Defendant(s):**
a. **Suncor Energy Inc.**, a corporation with its head office located at [Address].
b. **Imperial Oil Limited**, a corporation with its head office located at [Address].
c. **Canadian Natural Resources Limited**, a corporation with its head office located at [Address].
d. **Husky Energy Inc.**, a corporation with its head office located at [Address].
e. **Cenovus Energy Inc.**, a corporation with its head office located at [Address].
f. **Encana Corporation (Ovintiv Inc.)**, a corporation with its head office located at [Address].
g. **TC Energy Corporation**, a corporation with its head office located at [Address].
h. **Pembina Pipeline Corporation**, a corporation with its head office located at [Address].
i. **Enbridge Inc.**, a corporation with its head office located at [Address].
j. **Teck Resources Limited**, a corporation with its head office located at [Address].
k. [Include any other relevant oil companies].
### Facts
4. The defendants are major oil companies engaged in the extraction, production, refining, and sale of fossil fuels.
5. The defendants have long known about the environmental impacts of fossil fuel consumption, including climate change and pollution.
6. Despite this knowledge, the defendants have continued their activities without adequate measures to mitigate environmental harm.
7. The defendants have also engaged in misleading marketing practices, downplaying the risks associated with fossil fuel consumption.
### Legal Claims
8. The defendants have breached their duty of care to the plaintiffs and class members by:
a. Failing to take reasonable steps to prevent environmental damage.
b. Misleading the public about the environmental impact of their products.
c. Contributing to climate change and pollution, causing harm to health, property, and livelihoods.
9. The defendants' actions constitute:
a. Negligence
b. Public nuisance
c. Breach of statutory duty (reference specific environmental laws and regulations)
d. Unjust enrichment
### Damages
10. The plaintiffs and class members have suffered and continue to suffer:
a. Environmental damage, including but not limited to pollution of air, water, and soil.
b. Economic losses, including but not limited to property damage, increased living costs, and loss of income.
c. Health impacts due to exposure to pollutants and climate change effects.
### Relief Sought
11. The plaintiffs, on behalf of the class members, seek the following relief:
a. General and special damages for the harm suffered.
b. An order requiring the defendants to pay for the costs of environmental remediation.
c. An injunction preventing the defendants from continuing harmful practices.
d. Punitive damages to deter similar future conduct.
e. Any other relief that this Honourable Court deems just.
### Certification
12. The plaintiffs seek an order certifying this action as a class proceeding pursuant to the Class Proceedings Act, 1992, S.O. 1992, c. 6.
### Trial by Jury
13. The plaintiffs request a trial by jury.
---
**Dated:** [Date]
**[Plaintiff's Lawyer Name]**
**[Law Firm Name]**
**[Address]**
**[Contact Information]**
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