WINDSOR, Ont. - A 59-year-old Windsor, Ont., woman is denying allegations that she stole a $3.5-million winning lottery ticket from the bedside table of her 81-year-old husband and gave it to her daughter from a previous marriage.

In documents filed in Ontario Superior Court, Gerald Moore alleges Patricia Moore conspired along with family members to deceive him and claim the prize.

The suit alleges Moore stole her husband's winning ticket for the Lotto 6/49 draw on April 2, verified the winning numbers and gave it to her daughter Bobbie-Jo Arnold to cash in -- allegations Moore denies in a statement of defence.

The night after the lottery win, she told her husband she was going to spend the night at Arnold's house, the claim says.

"Under cover of darkness, (the defendants) rented a motor vehicle and drove to Toronto on or about April 4, 2008, for the sole purpose of claiming the winning prize monies," the husband's suit alleges.

When later questioned about the ticket, "(Moore) lied to (her husband), the Ontario Lottery and Gaming Corp., police investigators and others concerning her theft and unlawful agreement with her co-conspirators," the lawsuit reads.

Patricia Moore -- who the suit alleges was given $1.5 million of the winnings by Arnold -- filed for divorce from her husband at the beginning of August while he was at a fishing retreat in northern Ontario.

Arnold also gave another $1 million of her winnings to her sister and kept the remaining money for herself, the suit alleges.

The lawsuit, which also names the two sisters, other family members and the OLG, further alleges Moore manipulated her husband's "medication for the purpose of rendering him physically, emotionally and psychologically incapable of appreciating the nature and consequences of the events."

The allegations have not been proven in court.

A statement of defence, served Thursday and scheduled to be filed with the court Friday on behalf of Patricia Moore and her family members, counters Gerald Moore's version of events.

"The defendants state that the allegations made against them are false, reckless and entirely unfounded," the statement reads.

It states that Patricia Moore purchased the winning ticket for Arnold and brought it to her house on the day of the draw. Arnold then called her mother the next day to say she believed she had a winning ticket.

The money Patricia Moore received from her daughter's winnings went to pay off debts accumulated by her husband, as well a house bought in both of their names, the statement says.

Gerald Moore never accused his wife of stealing the lottery ticket but "one of his children made that allegation... for the first time, more than a month after (Moore) learned of the good fortune of Bobbie-Jo, which she shared with her sister and mother," the statements reads.

Gerald Moore's lawyer, Edward Posliff, concedes his client did not sign the lottery ticket -- a measure implemented by the OLG following an investigation that revealed an inordinate amount of "insider wins" by retailers.

Gerald Moore is seeking the full value of the lottery ticket in the lawsuit, Posliff added.

Lotteries across Canada have been under scrutiny since a scathing ombudsman's report blasted the OLG for not cracking down on retailers who collected tens of millions of dollars in jackpots between 1999 and 2006, some of them fraudulently.

The lawsuit alleges the OLG was negligent in failing to properly investigate the prize winner, including reviewing video and speaking with the retailer who sold the ticket.

An OLG spokesman confirmed lawyers for the gaming corporation have received a copy of the lawsuit and were reviewing the documents.