THIS IS A SEPARATION AGREEMENT DATED this ______ day of March, 2018.

Between

AMELIA ELIZABETH CARTWRIGHT

(hereinafter referred to as “Amelia” or “Wife” or “Mother”)
AND

ROBERT ARTHUR CARTWRIGHT

(hereinafter referred to as “Robert” or “Husband” or “Father”)

1. BACKGROUND

1.1 Amelia and Robert were married on April 25, 2009.

1.2 They separated on November 5, 2017. The parties will continue living separate
and apart.

1.3 They have two children, Liam Donald Cartwright, born September 17, 2011 and
Abigail Leah Cartwright, born April 26, 2013 (hereinafter referred to as "Children"
or “Child”).

1.4 Robert is employed as an accountant Durward, Jones & Barkwell and earns an
annual income of approximately $95,000. Amelia is employed as a server by
Betty’s Diner and earns an annual income of approximately $34,000.

1.5 They agree to be bound by this Agreement which settles all issues between them.

1.6 This Agreement replaces all oral or written agreements made between the parties.

2. DEFINITIONS

2.1 In this Agreement:

(a) "children" or “child” means Liam Donald Cartwright and Abigail Leah
Cartwright;

(b) "cohabit" means to live with another person in a relationship resembling

marriage;

(c) "equalization payment" means the payment referred to in s. 5(1) of the

Family Law Act;

www.DIVORCEmate.com 2016.10
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(d) "CRA" means Canada Revenue Agency;

(e) "FRO" means the Family Responsibility Office described in the Family
Responsibility and Support Arrears Enforcement Act, or any successor
support enforcement agency;

(f) "Guidelines" means the Federal Child Support Guidelines, as defined in s.

2(1) of the Divorce Act;

(g) "indexing factor" means the percentage change for a given month in the
Consumer Price Index for Canada for prices of All-Items (as published by
Statistics Canada) from the same month of the previous year;

(h) "matrimonial home" means the property at 85 Cole Crescent in Niagara on

the Lake, Ontario;

(i) "net family property" means net family property as defined in the Family Law
Act; and

(j) "property" means property as defined in the Family Law Act.

2.2 Any reference to a statute means the legislation bearing that name at the time the
Agreement is signed and includes its regulations and any amending or successor
legislation. For example, "Family Law Act" means the Family Law Act, R.S.O.
1990, c. F.3, as amended, and includes O.Reg. 391/97.

3. FREEDOM FROM THE OTHER

3.1 Amelia and Robert will directly or indirectly molest or disturb or annoy or interfere
with the other or the other’s business in any manner whatsoever, or attempt to
compel the other to cohabit or live with him or her.

4. PARENTING

(JOINT)

4.1 Amelia and Robert will have shared/joint custody of Liam Donald Cartwright and
Abigail Leah Cartwright.

4.2 Liam and Abigail will reside primarily with Amelia.

4.3 Liam and Abigail will reside secondarily with Robert on:
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(a) Wednesday evenings overnight from after school until the start of school on
Thursday morning;

(b) Alternate weekends, from Friday after school until the start of school on
Monday morning (access begins on Thursday if Friday is a school holiday
and ends on Tuesday morning if Monday is a school holiday); and

(c) Holiday residence schedule, as set out below.

4.4 This holiday access schedule is in addition to the regular access schedule above,
and overrides the regular access schedule in the event of conflict. (The regular
access schedule and the holiday access schedule are collectively referred to as
the “schedule”).

School Spring Break

(a) Liam and Abigail will stay with Amelia during the Spring Break in even-
numbered years and Robert in odd-numbered years, from their leaving
school as the Spring Break starts until their return to school following the
break.

Easter Weekend

(b) Liam and Abigail will stay with Amelia on Easter Weekend in even-
numbered years and Robert in odd-numbered years, leaving from their
school on the Thursday before the Easter Weekend until their return ti
school the following Tuesday.

Summer

(c) Each of the parties will have two non-consecutive weeks with the children.
Amelia will choose her weeks first in the odd-numbered years and Robert
will choose his weeks first in even-numbered years.

Thanksgiving Weekend

(d) Liam and Abigail will stay with Amelia on Thanksgiving weekend in odd-
numbered years and with Robert in even-numbered years, from their
leaving school on the Friday before Thanksgiving until their return to school
on the following Tuesday.
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Christmas Break

(e) Amelia and Robert will share the break evenly with Amelia having the
children for the first half of the break in odd-numbered years and the last
half of the break in even-numbered years. Robert will have the kids for the
first half of the break in even-numbered years and the last half in odd-
numbered years. Also, Amelia will always have the children on Christmas
Eve at noon to Christmas Day at noon and Robert will always have the
children form Christmas Day at noon until Boxing Day at noon.

Child's Birthday

(a) Each child will spend their birthday in accordance with the regular schedule.

4.5 The parent residing with Liam and Abigail at the relevant time will make the daily
decisions affecting their welfare.

4.6 Amelia and Robert will make important decisions about the children’s welfare
together, including decisions about their:

(a) education;

(b) major non-emergency health care;

(c) major recreational activities; and

(d) religious activities.

If the parties cannot agree, they will use the section of this Agreement entitled
“Dispute Resolution” to resolve the dispute.

4.7 With respect to the custody and access arrangement for the children set out above,
the parties further agree as follows:

(a) Both parties will provide each other with their email addresses, current
addresses and a phone number where they can be reached at all times.

(b) Robert's access will only be altered if both parties agree.

(c) With respect to the children’s transitions between the parties, the children
will be picked up or dropped off directly at school. When the children are
not in school, the party with the children will be responsible for dropping off
the children at the other party's home at 9:00 am unless otherwise specified,
at the commencement of the other party's time with the children.
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(d) If either party is unable to spend his or her scheduled time with Liam and
Abigail, he or she will be solely and financially responsible for making
alternate childcare arrangements.

(e) If either party is unable to spend his or her scheduled time with the children
will arrange a makeup time.

(f) Neither party will object to the other's plans with the children and must
respect each other's ability to care for Child appropriately.

(g) Neither party will arrange activities for the children during the other party's
scheduled time without the other party's consent.

(h) Both parties may attend extracurricular activities and scheduled school
events regardless of the schedule.

(i) If Liam and/or Abigail are sick, the transition from one party's care to the
other party's care is to proceed according to the schedule unless the child
is too sick to travel between the parties' homes according to the child’s
doctor.

(j) The children will be permitted to take any personal item, toy, gift or article
of clothing between the parties' homes, without restriction.

(k) The children’s health cards will travel with the children between the parties'
homes.

(l) If the children will be in the care of a third party for more than one overnight
during a party's scheduled time, that party will advise the other party by
email and will provide the name, address and phone number of the third
party.

(m) Notwithstanding the above subparagraphs, the parties will at all times
maintain a reasonable and flexible position respecting the custody/access
arrangements for Liam and Abigail and at all times the best interests of the
children will prevail. Accordingly, if special occasions, extracurricular
activities, excursions or other opportunities become available to any of the
children, or to either party, neither party will insist that the custody/access
arrangements set out herein be adhered to without exception.
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4.8 If a child needs emergency medical care while with one parent, that parent will
promptly notify the other of the emergency.

4.9 Amelia and Robert agree that it is in the children’s best interests to spend time with
the other parent rather than with a third party. Accordingly, if a party with whom the
children are scheduled to be according to the schedule above cannot care for the
children, that party will notify the other party and give the other party the opportunity
to do so. If the other party cannot care for the children, the party with whom the
children are scheduled to be according to the schedule above will be solely and
financially responsible for making alternate childcare arrangements.

4.10 Amelia and Robert may telephone the children on a once daily basis. The children
may telephone or email Amelia or Robert when they wish.

4.11 Amelia and Robert may make inquiries and be given information by the children’s
teachers, school officials, doctors, dentists, health care providers, summer camp
counsellors or others involved with the children. The parties intend this clause to
provide each of them with access to any information or documentation to which a
parent of a child would otherwise have a right of access. If, for whatever reason,
this clause itself is not sufficient (although both parties intend it to be sufficient
authority for either of them), the parties will cooperate and execute any required
authorization or direction necessary to enforce the intent of clause.

4.12 With respect to the children’s education, the parties agree as follows:

(a) Both parties may attend all school functions regardless of the schedule.

(b) The parties will attend parent-teacher meetings preferably together, but if
that is not practical, then individually.

(c) Each party will obtain his or her own school calendar and school notices.

(d) With respect to school field trips or classroom events, preferably together,
but if that is not practical, then individually.

4.13 If a party proposes to change their home residence within the Regional Municipality
of Niagara, the moving party will give particulars of their new address and
telephone number to the other.

4.14 Amelia and Robert will live near each other so that the children will have frequent
contact with both parties. Neither party will move the children’s permanent
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residence from Regional Municipality of Niagara without the other's written consent
or a court order.

4.15 The above-noted restriction on moving the children’s permanent residence is not
intended to limit the parties' ability to take the children out of the jurisdiction for the
purposes of travel with the children.

4.16 Amelia will apply for a Canadian passport for each child. Robert will sign the
passport applications. Amelia will keep the passports and give it to Robert when
he needs it for travel and he will return it promptly.

4.17 If either party plans a vacation with the children, that party will give the other a
detailed itinerary at least 30 days before it begins, including the name of any flight
carrier and flight times, accommodation, including address and telephone
numbers, and details as to how to contact the children during the trip.

4.18 If either party plans a vacation without the children, that party will give the other a
telephone number where he or she can be reached in case of emergency or if the
children wish to contact that parent.

4.19 If either party plans a vacation outside Canada with the children, the travelling party
will provide the other party with a travel consent authorizing the children to travel,
for the other party to execute and have notarized.

4.20 Amelia and Robert will not change the children’s name without the other's written
consent.

4.21 Amelia and Robert agree to:

(a) prefer the children’s interests to their own and at all times keep the best
interests of the children in mind;

(b) encourage the children to have a good relationship with each other and with
each party;

(c) refrain from making disparaging or negative remarks to the children about
the other party, and discourage others from doing so in the presence of the
children;

(d) exchange information and communicate about the children, such

communications to be by email, private, respectful, related solely to the
children, not shared with the children or third parties without the other's
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consent, and no more than once per day, except in the case of an
emergency;

(e) share all documents regarding the children by scanning the document and
then emailing it to the other party, rather than requiring the children to
transport documents between them;

(f) refrain from discussing with the children, or with a third party in the presence
of the children, present or past legal proceedings, issues between the
parties in any such legal proceedings or any conflicts between the parties;

(g) ensure that all information or documentation pertaining to the parties'

separation and divorce, including all personal correspondence or email
communications in respect thereof, is not accessible to the children;

(h) attend counselling together to improve their communication and parenting

skills;

(i) enroll the children in counselling to assist them in coming to terms with the
separation; and

(j) consult each other regularly about important issues such as the children’s
education, health care and religious upbringing.

5. CHILD SUPPORT

5.1 In this section:

(a) "Table" and "income" mean "Table" and "income" as those terms are
defined in s. 2(1) of the Guidelines;

(b) "special or extraordinary expenses" means "special or extraordinary

expenses" as this phrase is defined in s. 7(1) of the Guidelines;

(c) "child support" refers to the monthly amount upon which the parties have
agreed and may include both Table support and special or extraordinary
expenses.

5.2 For purposes of determining child support for Liam and Abigail, Robert's annual
income is $100,000 and Amelia's annual income is $38,000.

5.3 Robert will pay to Amelia as child support for Liam Donald Cartwright born
September 17,2011, and Abigail Leah Cartwright born April 26, 2013:
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(a) the Table amount of $2,400, starting April 1,2018 and on the first day of
each month thereafter; and

(b) his share of the special or extraordinary expenses as set out in the
applicable special or extraordinary expenses sections below;

until a terminating event under the termination section 5.7 or a change in child
support under the sections that follow.

5.4 Robert will pay to Amelia 72 percent of the children’s special or extraordinary
expenses within five days of Amelia delivering proof to him of the expense. In
determining his contribution to the expense, Robert may deduct any income tax
benefit or other subsidy received by Amelia for that special or extraordinary
expense.

5.5 The parties will only contribute to the children’s special or extraordinary expenses
if the parties consent to the expenses in advance, in writing. Neither party will
unreasonably withhold consent. If the parties cannot agree, they will use the
section of this Agreement entitled "Dispute Resolution" to resolve this issue.

5.6 The parties each support Child without contribution from the other. Any application
of the Guidelines would result in an amount of child support that is inappropriate.
The parties' present child support arrangements are reasonable and meet the
objectives of the Guidelines.

5.7 Child support ends for Liam and Abigail when:

(a) The child ceases to be a "child" as defined in the Divorce Act;

(b) The child no longer resides with the custodial parent, ("resides" includes the
child living away from home for school, summer employment or vacation);

(c) The child turns 18, unless he or she is unable to become self-supporting
due to illness, disability, education or other cause;

(d) The child becomes self-supporting;

(e) The child obtains one post-secondary degree or diploma;

(f) The child turns 18 years of age;

(g) The child marries;

(h) The child dies; or

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(i) a party dies, provided that the security in the section of this Agreement
entitled "Life Insurance" is in place at the time of death.

5.8 Prior to determining each party's obligation to the child's post-secondary

educational costs, Amelia and Robert shall first deduct a reasonable contribution
to these expenses expected from the child. The source of the child’s contribution
shall include, but is not limited to, savings, trust funds, investments, gifts, summer
or part-time employment, scholarship, loans and bursaries. In the event that
Amelia and Robert cannot agree on the child's reasonable contribution to these
expenses, they will use the section of this Agreement entitled "Dispute Resolution"
to resolve the issue.

5.9 If Robert's obligation to support a child ends, the parties will determine the support
payable for the other child at that time under the Guidelines and will use the section
of this Agreement entitled "Dispute Resolution" to resolve the issue.

5.10

(a) On or before June 1st of each year, commencing in the year following the
execution of this Agreement, the parties will exchange income information
for the prior calendar year. They will use this information to adjust the child
support payable, including both the Table Amount and the proportionate
sharing of the children's special or extraordinary expenses.

(b) Any change in the Table Amount and the proportionate sharing of the
special or extraordinary expenses will commence on July 1st of each year,
commencing in the year following the execution of this Agreement. If the
parties do not agree about any change in child support, they will use the
section of this Agreement entitled "Dispute Resolution" to resolve the
issue(s).

5.11 Robert will pay the child support directly to Amelia and not to the Family
Responsibility Office. Neither party will file this Agreement with the Family
Responsibility Office for enforcement unless Robert defaults in payment and does
not pay within five days of getting a written notification from Amelia, at which time
she may file the Agreement with the court and the Family Responsibility Office for
enforcement.

6. SPOUSAL SUPPORT RELEASE

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6.1

(a) As a result of the terms of this Agreement, Amelia and Robert are financially
independent of each other and release his or her rights to spousal support
from the other, now and forever.

(b) Amelia and Robert intend this Agreement to be forever final and non-
variable.

(c) For greater certainty, the parties acknowledge that:

(i) they have negotiated this Agreement in an unimpeachable fashion

and that the terms of this Agreement fully represent their intentions
and expectations;

(ii) they have had independent legal advice and all the disclosure they
have requested and require to understand the nature and
consequences of this Agreement, and to come to the conclusion, as
they do, that the terms of this Agreement, including the release of all
spousal support rights, reflect an equitable sharing of the economic
consequences of their relationship and its breakdown;

(iii) the terms of this Agreement substantially comply with the overall
objectives of the Divorce Act now and in the future;

(iv) they require the courts to respect their autonomy to achieve certainty
and finality in their lives;

(v) the terms of this Agreement and, in particular, this release of spousal
support, reflect his and her own particular objectives and concerns,
and are intended to be a final and certain settling of all spousal
support issues between them. Among other considerations, they are
also relying on this spousal release, in particular, upon which to base
their future lives.

(d) Amelia and Robert specifically wish to be able to pursue their separate and
independent lives, no matter what changes may occur. Amelia and Robert
specifically anticipate that one or both of them may lose their jobs, become
ill and be unable to work, have additional child care responsibilities that will
interfere with their ability to work, find their financial resources diminished
Separation Agreement Page 12

or exhausted whether through their own fault or not, or be affected by

general economic and family conditions changing over time. Changes in
their circumstances may be catastrophic, unanticipated or beyond their
imagination. Nevertheless, no change, no matter how extreme or
consequential for either or both of them, will alter this Agreement and their
view that the terms of this Agreement reflect their intention to always be
separate financially. Amelia and Robert fully accept that no change
whatsoever in either or both of their circumstances will entitle either of them
to spousal support from the other, now and forever.

(e) In short, the parties expect the courts to enforce fully this spousal support
release no matter what occurs in the future.

7. MEDICAL AND DENTAL BENEFITS

7.1 In this section:

"medical" means all mental and physical health needs, including prescriptions,
vision care, psychological counselling, dental and orthodontic costs, chiropractic
costs, speech therapy, occupational therapy, physiotherapy, homeopathy,
acupuncture and massage therapy.

7.2 While required to pay child support under this Agreement, Robert will maintain the
children as beneficiaries of medical, extended health and dental coverage through
his employment for as long as it is available to him.

7.3 While required to pay spousal support under this Agreement, Robert will maintain
Amelia as beneficiary of medical, extended health and dental coverage through
his employment for so long as it is available to him.

7.4 Robert will:

(a) promptly submit receipts given to him by Amelia to the insurer; and

(b) immediately endorse the reimbursement cheques from the insurer to

Amelia and deliver them to her.

7.5 If Robert's employer no longer makes medical, extended health or dental coverage
available, Robert will immediately tell Amelia. He will also immediately purchase
private medical, extended health and dental insurance for Amelia and the children
of available to him at a comparable or reasonable cost.
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7.6 Medical expenses not covered by either party's extended health insurance are
special or extraordinary expenses and will be paid according to the applicable
special or extraordinary expense sections above.

7.7 After the obligation to pay child support ends, Robert may remove the child's name
from their extended health insurance coverage.

7.8 Robert will repay Amelia for any expense or loss she incurs because of Robert's
failure to maintain medical, extended health or dental coverage as required by this
Agreement.

8. LIFE INSURANCE

8.1 Robert owns or has an interest in a policy of term life insurance his employment at
Durward, Jones & Barkwell, in the amount of $300,000 (the "policy"). Robert
warrants that he has not borrowed against the policy and that the full face value of
the policy is available and unencumbered.

8.2 Robert will pay all policy premiums when due. If he does not and Amelia pays any
premiums, interest or penalties to prevent the lapse of the policy, those amounts
will be considered lump sum child support and enforceable against Robert. If the
policy lapses because Robert failed to pay the premiums, Robert will also pay
Amelia all necessary costs incurred by herD to reinstate the policy.

8.3 As long as Robert is obligated to pay child support in accordance with this
Agreement, Robert will:

(a) keep the policy in force;

(b) not borrow against the policy and will ensure that the policy remains
unencumbered; and

(c) irrevocably designate and maintain Amelia as the beneficiary of the

proceeds of the policy;

as security for Robert's child and/or spousal support obligations outstanding as

at the date of Robert's death pursuant to this Agreement.

8.4 Prior to signing this Agreement:

(a) Robert will provide Amelia with a copy of the policy and the irrevocable
beneficiary designation; and
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(b) Robert signed a direction permitting Amelia to confirm directly with Robert's
employer and insurer that the policy is unencumbered and in force.

8.5 Within 14 days of each anniversary date of the policy, Robert will give Amelia proof
that he has paid the premium.

8.6 If Robert's policy cannot be maintained for any reason, he will immediately obtain
replacement coverage at a reasonable cost, ensuring no gap in coverage. If
Robert learns that there may be a change in insurance coverage, he will advise
Amelia of the proposed change in coverage and the reason for the change.

8.7 If the policy or the full amount of the policy is not in force on Robert's death:

(a) Robert authorizes a lien and first charge against his estate for the full
amount of the policy proceeds;

(b) all of Amelia's rights and remedies against Robert's estate are preserved.

9. MATERIAL CHANGE IN CIRCUMSTANCES

The amount of the payment and the terms for payment as provided by this
agreement for the support of the children, or any child, may be varied:

(i) Prior to the granting of a divorce, if there is a change in

circumstances such that a court of competent jurisdiction in the same
circumstances would vary an Order for support made in the same
amount and terms under the Family Law Act on the effective date of
this agreement;

(ii) After a divorce is granted, if there is a change in circumstances of

Amelia or Robert such that a court of competent jurisdiction in the
same circumstances would vary and order or support made in the
same amount and terms under the Divorce Act on the effective date
of this Agreement.

(iii) If either Amelia or Robert is entitled to a variation the variation made

(1) May be the discharge, variation or suspension of a term of the

obligation or pay prospectively or retroactively, and

(2) May relieve Robert from the payment of part or all of any
arrears, and
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(3) May provide, prospectively or retroactively, for an increase or

decrease in the amount of the payment to be made to Amelia
for her support or for the support of the children or any child.

(iv) Any difference or dispute between Amelia and Robert as to what, if

any, variation should be made shall be resolved under the section of
this Agreement providing for the RESOLUTION OF DISPUTES.

10. EQUALIZATION

10.1 Within five days of the signing of this Agreement, Robert will make a payment of
$75,000 by certified cheque delivered before April 1, 2018 to Amelia at 85 Cole
Crescent, Niagara on the lake, Ontario.

10.2 This payment is an equalization payment in full satisfaction of all claims under Part
I of the Family Law Act.

11. HOUSEHOLD GOODS AND PERSONAL EFFECTS

11.1 Each of the parties acknowledges that,

(a) The contents of the matrimonial home, including furniture, furnishings,

household goods, silverware, china, glassware, rugs, books, pictures, bric-
a-brac and all other household effects have been divided between the
parties or have been purchased or the value set off against the value of
other property by one of the parties to the satisfaction of each of them;

(b) Each has possession of his or her jewellery, clothing and personal effects;

(c) Each may dispose of the items possessed by him or her as he or she deems
fit.

12. VEHICLES AND OTHER FAMILY PROPERTY

12.1 Amelia is entitled the all the right, title and interest in all assets in his possession,
including but not limited to:

(a) Her teacup collection

(b) Her 2017 Kia Sedona

free and clear of any claim thereto by Robert.

Separation Agreement Page 16

12.2 Robert is entitled the all the right, title and interest in all assets in his possession,
including but not limited to:

(a) His sports memorabilia

(b) His camping equipment

(c) His 2010 Volkwagen Jetta

free and clear of any claim thereto by Amelia.

13. MATRIMONIAL HOME

13.1 The parties own the matrimonial home as joint tenants.

13.2 The parties agree that the property shall be listed for sale forthwith with a real
estate agent agreed to by the parties for a price agreed to by the parties. Upon
sale of the matrimonial home, the net sale proceeds, after payment of the real
estate commission, if any, the legal fees pertaining to the sale, and all
encumbrances registered on title, shall be divided equally between the parties.

13.3 During the period that the property is listed for sale, Amelia shall reside at the
property and shall be responsible for paying all mortgage payments, taxes,
insurance premiums, heating, water and other charges related to the matrimonial
home, and shall save Robert harmless from all liability for those payments.

14. DEBTS

14.1 Amelia and Robert have the following debts in their joint names:

(a) Line of Credit with TD Canada Trust in the approximate amount of $10,000,
and;

(b) Line of Credit with Bank of Montreal in the approximate amount of $8,000;

14.2 Amelia will be responsible for the TD Canada Trust Line of Credit.

14.3 Robert will be responsible for the Bank of Montreal Line of Credit.

14.4 If Amelia or Robert becomes liable for a debt the other has assumed, the party
who has assumed the debt will fully indemnify the other.

14.5 Amelia and Robert will each be solely responsible for payment of each one's own
personal debts and liabilities, which include:
Separation Agreement Page 17

(a) Amelia’s Loan to her mother in the approximate amount of $2,000;

(b) Amelia’s Car Loan with TD Canada Trust in the approximate amount of
$12,000; and

(c) Robert’s debt to the Canada Revenue Agency in the approximate amount
of $5,800,

and will indemnify the other from any expense or liability with respect to each one's
own personal debts and liabilities.

14.6 When this Agreement is signed, Amelia and Robert will terminate the following joint
credit cards:

(a) TD Canada Trust Visa, # 4561 4540 6186 2600;

(b) RBC Royal Bank, # 4510 8481 8964 6565;

(c) Capital One Master Card, # 4615 8965 8635 5151; and

Amelia will be responsible for any balance owing on Capital One Master Card, #
4615 8965 8635 5151.

Robert will be responsible for any balance owing on TD Canada Trust Visa, # 4561
4540 6186 2600 and RBC Royal Bank, # 4510 8481 8964 6565.

14.7 Amelia and Robert are both liable to RBC Royal Bank for the mortgage registered
against the matrimonial home. Amelia will assume full responsibility for this debt
and will use her best efforts to arrange Robert's release from it. Whether or not
Amelia is able to arrange Robert's release, she will fully indemnify him from the
debt.

14.8 Neither Amelia nor Robert will pledge the credit of the other or bind the other for
any debts either may incur after the signing of this Agreement. Amelia and Robert
acknowledge that they have not pledged the credit of the other since separation.

14.9 A party who is under an obligation in this Agreement to reimburse or indemnify the
other will:

(a) pay the other's expenses, damages or loss, including costs arising from the
party's obligation to reimburse or indemnify; and

(b) indemnify the other from:

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(i) any amounts paid by the other with respect to the liability, plus
interest on the amount at two percent a year compounded annually;
and

(ii) actual legal fees and disbursements incurred by the other.

15. DISPUTE RESOLUTION

15.1 If Amelia and Robert disagree about a reviewable or variable term of this
Agreement, they will first try to resolve the dispute through negotiation, either
between themselves or with their respective counsel, on the following terms:

(a) The party seeking a change, will make the request for review or variation by
giving the other, in writing:

(i) notice of the proposed change;

(ii) evidence supporting the proposed change; and

(iii) any requests for information from the other necessary to determine
the issue.

(b) A request under subsection (a) above will be answered within thirty days.

(c) After exchanging any information required by this Agreement, Amelia and
Robert will meet personally to resolve the issues in dispute. If they come to
an agreement, Amelia and Robert will sign and date an amending
agreement before witnesses.

15.2 If Amelia and Robert are unable to resolve the dispute through negotiation within
thirty days of the request for review or variation, they will mediate the issue on the
following terms:

(a) The parties will select a mutually agreeable mediator.

(b) The parties will share the cost of mediation equally.

15.3 If Amelia and Robert are unable to resolve the dispute through negotiation and/or
mediation within twenty days of the commencement of meditation, either party may
bring an application to the court to resolve the dispute. Except in the case of an
emergency, the party making an application to the court will give the other party
no less than twenty days' notice of the application.
Separation Agreement Page 19

16. PENSIONS

16.1 In this Part of the Agreement:

(a) "Family Law Valuation Date" means the date the parties separated with no
reasonable prospect of resuming cohabitation;

(b) "Family Law Value of 's pension interests" means the imputed value, for
family law purposes, of 's pension benefits, deferred pension or
pension/lifetime pension under the Plan, accrued from the starting date to
the Family Law Valuation Date, as determined pursuant to the Family Law
Act, the PBA and the PBA Regulation, and valued in the Pension Form
4(letter);

(c) "Family Law Value of 's survivor benefits" means the imputed value, for
family law purposes, of 's survivor benefits under the Plan, accrued from the
starting date to the Family Law Valuation Date, as determined pursuant to
the Family Law Act, the PBA and the PBA Regulation, and valued in the
Pension Form 4E;

(d) "PBA" means the Pension Benefits Act;

(e) "PBA Regulation" means Ontario Regulation O.Reg. 287/11, relating to

Family Law Matters, pursuant to the PBA;

(f) "pension" or "lifetime pension" (as it is sometimes referred to in the Pension

Forms) means 's pension under the Plan that is in payment;

(g) "Pension Form(s)" means the FSCO Family Law Form(s) prescribed by the
PBA and the PBA Regulation, more particularly delineated by a number;

(h) "starting date" means the starting date for determining the Family Law
Value, pursuant to the PBA Regulation;

(i) "surplus" means the excess of the value of the Plan's assets over its
liabilities, as more particularly defined in the PBA;

(j) "transfer ratio" means the transfer ratio as defined in the PBA which reflects
the funded status of the Plan as of a certain date.

17. BANKRUPTCY ACT

Separation Agreement Page 20

17.1 The parties acknowledge and agree that any lump sum equalization payment or
payments shall be a domestic obligation within the meaning of the Bankruptcy Act
and will not merge on a bankruptcy of either party.

18. RELEASES

18.1 In consideration of and on completion of the parties' mutual obligations in this

Agreement, and except as otherwise provided in this Agreement, Amelia and
Robert:

(a) release each other from all claims either may have against the other now or
in the future under the terms of any statute, in equity or the common law,
including all claims under the Divorce Act, the Family Law Act, and the
Succession Law Reform Act, for:

(i) possession of property;

(ii) ownership of property;

(iii) division of property;

(iv) compensation for contributions to property;

(v) monetary or proprietary remedies for unjust enrichment including

claims where there is a joint family venture;

(vi) claims in trust, including any claims to a constructive or resulting

trust; and

(vii) an equalization payment.

(b) will be entitled to retain their respective property free from any claim by the
other party, and will be free to deal with or dispose of their respective
property as they deem fit;

(c) will not claim any share or interest in the other party's property;

(d) in the case of RRSPs, RRIFs, registered or unregistered private or

employment pensions, life insurance and any such similar property,
disclaim any and all rights arising from and benefits payable to them from
the other party's plans, including any survivor benefits and other rights or
benefits which may arise on the death of the other, or any designations to
the contrary that predate this Agreement.
Separation Agreement Page 21

18.2 Except as otherwise provided in this Agreement, Amelia and Robert each
renounce any entitlement either may have in the other's will made before the date
of this Agreement or to share in the estate of the other upon the other dying
intestate.

18.3 Except as otherwise provided in this Agreement, Amelia and Robert release each
other from all claims either may have against the other now or in the future under
the terms of any statute or the common law, including claims for:

(a) a share in the other's estate;

(b) a payment as a dependant from the other's estate under the Succession
Law Reform Act;

(c) any entitlement under the Family Law Act;

(d) an appointment as an attorney or guardian of the other's personal care or

property under the Substitute Decisions Act; and

(e) participation in decisions about the other's medical care or treatment under
the Health Care Consent Act.

18.4 Except as otherwise provided in this Agreement, on the death of either party:

(a) the surviving party will not share in any testate or intestate benefit from the
estate;

(b) the surviving party will not act as personal representative of the deceased;
and

(c) the estate of the deceased party will be distributed as if the surviving party
had died first.

19. AGREEMENT

19.1 Amelia and Robert each acknowledges and agrees that this Agreement is a
separation agreement entered into under section 54 of the Family Law Act, and is
a domestic contract that prevails over all matters dealt with in the Family Law Act.

19.2 There are no representations, collateral agreements, warranties or conditions

affecting this Agreement. There are no implied agreements arising from this
Agreement and this Agreement between the parties constitutes the complete
agreement between them.
Separation Agreement Page 22

20. RECONCILIATION

20.1 If Amelia and Robert attempt to reconcile their relationship, but cohabit for no
longer than 90 days, this Agreement will not be affected. If they cohabit for more
than 90 days, this Agreement will become void, except that any transfers or
payments made to that time will not be affected or invalidated.

21. SEVERABILITY

21.1 Except as otherwise provided in this Agreement, the invalidity or unenforceability

of any term of this Agreement does not affect the validity or enforceability of any
other term. Any invalid term will be treated as severed from the remaining terms.

22. HEADINGS

22.1 The section headings contained in this Agreement are for convenience only and
do not affect the meaning or interpretation of any term of this Agreement.

23. DIVORCE

23.1 If a divorce judgment or order issues, all of the terms of this Agreement will
continue.

24. FINANCIAL DISCLOSURE

24.1 Amelia and Robert have disclosed their income, assets and other liabilities existing
at the date of April 25, 2009, separation and the date of this Agreement.

24.2

(a) Each party has investigated the other's financial circumstances and is
satisfied with the disclosure and investigation.

(b) The parties acknowledge that their respective solicitors have drawn their
attention to section 56(4)(a) of the Family Law Act, that provides as follows:

"56(4) A court may, on application, set aside a domestic contract or a

provision in it,

(a) if a party failed to disclose to the other significant assets, or

significant debts or other liabilities, existing when the domestic contract
was made."
Separation Agreement Page 23

25. STRICT PERFORMANCE

25.1 Amelia or Robert's failure to insist on the strict performance of any terms in this
Agreement will not be a waiver of any term.

26. COSTS

26.1 The parties will pay their own costs for the negotiation and preparation of this
Agreement.

27. INDEPENDENT LEGAL ADVICE

27.1

(a) Amelia and Robert have both had independent legal advice, Amelia from
Marie D’Ajurck and Robert from Bo Peep.

(b) Amelia and Robert:

(i) understand their respective rights and obligations under this

Agreement and its nature and consequences;

(ii) acknowledge that this Agreement is fair and reasonable;

(iii) acknowledge that they are not under any undue influence or duress;
and

(iv) acknowledge that both are signing this Agreement voluntarily.

28. GENERAL TERMS

28.1 The interpretation of this Agreement is governed by the laws of Ontario.

28.2 This Agreement survives the death of Amelia and Robert and enures to the benefit
of and binds Amelia and Robert's heirs, executors, estate trustees, personal
representatives and assigns.

28.3 Amelia and Robert will each inform the executors, estate trustees, personal
representatives named in each one's will that this Agreement exists, and where a
copy is located.

28.4 Any amendments to this Agreement must be in writing, signed by the parties, dated
and witnessed.
Separation Agreement Page 24

28.5 Amelia and Robert will sign any documents necessary to give effect to this
Agreement.

28.6 This Agreement was prepared jointly by both parties and their solicitors.

29. EFFECTIVE DATE

29.1 The effective date of this Agreement is the date on which the latter party signs it.

TO EVIDENCE THEIR AGREEMENT AMELIA AND ROBERT HAVE SIGNED THIS

AGREEMENT BEFORE A WITNESS.

DATE: March 23, 2018

_________________________ _________________________
WITNESS AMELIA ELIZABETH CARTWRIGHT

DATE:

_________________________ _________________________
WITNESS ROBERT ARTHUR CARTWRIGHT
 CERTIFICATE OF INDEPENDENT LEGAL ADVICE

I, Marie D’Ajurck, of the City of Welland in the Regional Municipality of Niagara, in

the Province of Ontario, Barrister and Solicitor, certify that I was consulted by Amelia
Elizabeth Cartwright, one of the parties to the attached Separation Agreement with
respect to her rights and obligations under this Agreement.

I acted only for Amelia Elizabeth Cartwright and fully explained to her the nature
and effect of the Agreement. Amelia Elizabeth Cartwright acknowledged that she
completely understood the nature and effect of the Agreement. Amelia Elizabeth
Cartwright executed the Agreement in front of me and confirmed that she was entering
into the Agreement of her own volition without any fear, threats, compulsion or influence
by Robert Arthur Cartwright or any other person.

Dated at Welland, Ontario this March 23, 2018:

______________________________
MARIE D’AJURCK
 CERTIFICATE OF INDEPENDENT LEGAL ADVICE

I, Bo Peep, of the City of St. Catharines in the Regional Municipality of Niagara, in

the Province of Ontario, Barrister and Solicitor, certify that I was consulted by Robert
Arthur Cartwright, one of the parties to the attached Separation Agreement with respect
to his rights and obligations under this Agreement.

I acted only for Robert Arthur Cartwright and fully explained to him the nature and
effect of the Agreement. Robert Arthur Cartwright acknowledged that he completely
understood the nature and effect of the Agreement. Robert Arthur Cartwright executed
the Agreement in front of me and confirmed that he was entering into the Agreement of
his own volition without any fear, threats, compulsion or influence by Amelia Elizabeth
Cartwright or any other person.

Dated at St. Catharines, Ontario this March , 2018:

______________________________
BO PEEP
DATED: March , 2018

Between:

AMELIA ELIZABETH CARTWRIGHT

and

ROBERT ARTHUR CARTWRIGHT

SEPARATION AGREEMENT

D’AJURCK & BOWMAN

32 Main Street West
Welland, Ontario L5S 8E5
Tel: (905)-768-7785
Fax: (905)-768-7789