CLAIM FOR

Form 1 [Rule 8.1(3)]

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

IN THE COMMERCIAL DIVISION
BETWEEN BELINDA BRADFORD CLAIMANT

AND DECADENT DECORATING SPECIALIST DEFENDANT

LIMITED

CLAIM NO. SU2022CD0987

The Claimant BELINDA BRADFORD ,a Senior Decorating Specialist of Rose Hall

District, Linstead P.O. in the parish of Saint Catherine, claims against the Defendant,
DECADENT DECORATING SPECIALIST LIMITED with offices located at Mount
Zion Road, Rock River in the parish of Clarendon to recover damages in the amount of
Seventeen Thousand Five Hundred United States Dollars ($17,500.00) plus interest at
6% per annum for Breach of Contract and Unjust Enrichment in that, in or around
August 19, 2022 the Claimant and the Defendant entered into a contract for the
Claimant to complete jobs assigned to her by the Company’s Directors and to bring in
work of her own for which she would be paid 10% commission on the fees payable to the
company. The Defendant’s office located at Mount Zion Road, Rock River in the parish
of Clarendon. The parties agreed that the Claimant would be paid for the value of the
work done however, the Defendant has failed and or refused to pay the Claimant for the
value of the work done by the Claimant, causing loss and damage and causing the
Claimant to incur expenses.

AND THECLAIMANT CLAIMS:

a. The sum of US$17,500.00) as damages for breach of contract and unjust
enrichment;
b. Interest on the sum of US$ 17,500.00) at the rate of 6% per annum pursuant
to the Law Reform (Miscellaneous Provisions) Act and continuing at that rate
until Judgment or sooner payment;
c. Costs; and

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 d. Such further and other relief as this Honourable Court may deem fit.

CERTIFICATE OF VALUE
That the Claimant certifies that to the best of his knowledge, information and belief the
damages claimed exceed the civil jurisdiction of the Parish Court.

CERTIFICATE OF TRUTH
I Desmond Louden certify that all facts set out in this Claim Form are true to the
best of my knowledge, information and belief.

Dated the day of 2023

BELINDA BRADFORD

CLAIMANT

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 PARTICULARS OF CLAIM

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

IN THE COMMERCIAL DIVISION
CLAIM NO. SU2022CD0987
BETWEEN BELINDA BRADFORD CLAIMANT

AND DECADENT DECORATING SPECIALIST LIMITED DEFENDANT

1. The Claimant, BELINDA BRADFORD, was at all material times a Senior

Decorating Specialist of Rose Hall District, Linstead P.O. in the parish of Saint
Catherine.

2. The Defendant, DECADENT DECORATING SPECIALIST LIMITED with

offices located at Mount Zion Road, Rock River in the parish of Clarendon was at
all material times the owner of the DECADENT DECORATING SPECIALIST
LIMITED located at Mount Zion Road, Rock River in the parish of Clarendon.

3. In or about August 19, 2022 the Claimant and the Defendant entered into a
contract for the Claimant to complete jobs assigned to her by the Company’s
Directors and to bring in work of her own for which she would be paid 10%
commission on the fees payable to the company. The parties initially agreed that
the Claimant would be paid an annual basic salary of US$250,000.00.

4. That the Claimant substantially brought in 8 clients earning the Defendant US$
125,000.00 however, contrary to Claimant contract, she was never paid the
commission. Thereafter, the Defendant terminated the agreement with the
Claimant and several effort was made by the Claimant to have a meeting with the
Director of the Company which all was futile.

5. That the Director of the Company have failed to provide the Claimant with the
proper reason why her contract was terminated.

6. That the Claimant engaged the services of Trendsetter Legal Attorney-at-Law, to

represent her in a law suit against the Defendant.

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 7. The Defendant has benefitted from the eight (8) clients recommended to the
company by the Claimant and the Defendant has been enriched by the increased
value provided at the Claimant’s expense as the Claimant has to date not been
paid the said commission for the eight (8) client.

8. Despite the Claimant’s continual requests for payment, the Defendant has failed
and/or refused to satisfy the outstanding payment due to the Claimant for the
clients recommend by the Claimant.

9. The Defendants failure and/or refusal to satisfy the outstanding payment due to
the Claimant amounts to a flagrant breach of the contractual arrangement made
between the Defendant and the Claimant and/or the Defendant’s unjust
enrichment.

10. By reason of the matters aforesaid, the Claimant has suffered direct loss as a
result of the Defendant’s breach and/or actions.

PARTICULARS OF LOSS OF THE CLAIMANT

PARTICULARS US$
Commissioned Owed $12,500.00
Attorney Fees to draft Claim $ 5,000.00

GRAND TOTAL $ 17,500.00

11. The Claimant is entitled to recover all the sums which have accrued based on her
reliance on the terms of the agreement and her performance of her obligations
under the said agreement with the Defendant.

12. Further, the Claimant claim interest on all outstanding amounts due at 6% per
annum pursuant to the Law Reform (Miscellaneous Provisions) Act from the
dates of issue of the said invoices and continuing at that rate until Judgment or
sooner payment.

AND THE CLAIMANT CLAIMS:

e. The agreed sum of US$17,500.00 as damages for breach of contract and
unjust enrichment;
f. Interest on the sum of US$17,500.00 at the rate of 6% per annum pursuant to
the Law Reform (Miscellaneous Provisions) Act and continuing at that rate
until Judgment or sooner payment;

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 g. Costs; and
h. Such further and other relief as this Honourable Court may deem fit.

CERTIFICATE OF VALUE
That the Claimant certifies that to the best of her knowledge, information and belief the
damages claimed exceed the civil jurisdiction of the Resident Magistrate’s Court.

CERTIFICATE OF TRUTH
I certify that all facts set out in this Particulars of Claim are true to the best of my
knowledge, information and belief.
Dated the day of 2023

BELINDA BRADFORD

Filed by TRENDSETTER LEGAL Attorneys-at-Law for and on behalf of the Claimant

whose address for service is Suite # 11, Winchester Business Centre, 15 hope
Road,Kingston 10, telephone numbers 908-2207, 908-0589, 754-6745 and 754-9596
and fax number is 906-5404. Email: thelaw1019@gmail.com.