Claims By or Against Estates Expire After Two Years

by: and , May 14, 2014

The decision of the Ontario Divisional Court in Cerqueira Estate v Ontario provides a useful discussion of the differences between the limitation periods in the Limitation Act and in the Trustee Act.  Whereas limitation periods under the Limitations Act begin running as soon as the cause of the claim is discovered (the principle of discoverability),…read more

Increasing Access to Justice through Orders for Directions

by: and , May 13, 2014

The Supreme Court of Canada has emphasized access to justice as one of the top concerns facing the legal profession today (see our blog post summarizing the Supreme Court’s decision, Hryniak v Mauldin).  Justice Brown of the Ontario Superior Court has made practical the Supreme Court’s directives in Re Estate of Ireni Traitses. Re Estate…read more

You Can’t Have It All: Hybrid Trials, Limited Discovery, and Modest Estates

by: , May 8, 2014

Lorraine Coombs died on April 27, 2012, leaving an estate worth approximately $756,249.00.  Her Last Will and Testament left her house and the residue of her estate to one of her four daughters, Susan Coombs (“Susan”).  Two of her other daughters, Diane Fergueson (“Diane”) and Charlene Coombs (“Charlene”), each received $60,000 and another daughter, Donna…read more

What Not to Wear: Court Edition

by: , December 16, 2013

Effective November 18, 2013, there are some important procedural changes affecting estate, trust, and capacity matters in Toronto. For some time now, the Toronto court has maintained a separate “Estates List” to hear all matters relating to the administration of trusts and estates and substitute decision making.  As an estates litigator, I have been an…read more

Proper Lawyer Behaviour on Discovery, in the Age of Rob Ford

by: , November 20, 2013

Examinations for discovery can afford an excellent opportunity to determine the strength of the opposing party’s position. The discovery process also provides a chance to see a lawyer’s oral advocacy skills in action. But sometimes, a lawyer’s behaviour has the effect of disrupting the discovery process. In Tondera v. Vukadinovic, 2013 ONSC 6888 (CANLii), defence counsel…read more

Lawyer’s Questionnaire Admitted to Probate as a Will

by: , November 4, 2013

Courts are sometimes asked to determine if a “testamentary-like” document is a will.  In British Columbia, an executor brought an action to prove in solemn form that a questionnaire that the testator (“Ms. Garnett”) filled out and signed before two witnesses shortly before her death was a will that could be submitted for probate. Ms. Garnett was…read more

If There is a Valid POA, the Court Cannot Order a Guardianship

by: , September 30, 2013

The recent decision in Lehtonen v. Neill serves as a useful reminder of the sometimes overlooked subsection 22(3) of the Substitute Decisions Act.   This provision prohibits the court from appointing a guardian where the court is satisfied that decision making for the incapable person can be met by a less intrusive means.  It says: The Court shall not…read more

Post Security or Go Home

by: , September 20, 2013

You don’t often hear about a motion for security for costs in estate litigation (if nothing else the parties are usually very much present in the jurisdiction and have some financial worth).  However, estate litigants have been ordered to post security for costs just as in any other civil litigation.  Equally, estate litigants have successfully…read more

When Is It Too Late To File A Notice Of Objection To The Appointment Of An Estate Trustee?

by: , August 26, 2013

In a recent case, the court had to determine if a notice of objection to the issuance of an appointment of an estate trustee could be filed after summary judgment had been granted, striking another objector’s objections as invalid and a certificate of appointment had been issued to the estate trustees. By way of background, the…read more

Keep the Trains Running: The Importance of a Status Hearing

by: , July 30, 2013

In a recent decision by the Ontario Court of Appeal, the court turned its attention to a frequently encountered issue in civil litigation: under what circumstances should an action be dismissed  for delay by the court following a status hearing?  The appellant (plaintiff) appealed a lower court order dismissing the action for delay after a status hearing….read more