On July 26, 2017, the plaintiff, a lawyer for Legal Aid Ontario, submitted a claim for long-term disability benefits (LTDs) to Sun Life Assurance Company of Canada (Sun Life), alleging total disability as of April 18, 2017, due to left arm and shoulder pain, anxiety, depression and phantom limb pain. On September 26, 2017, the plaintiff received a letter from Sun Life advising her that her claim for LTDs had not been approved as she did not satisfy the definition of “total disability”.