WEL Newsletter, Vol. 10, No. 1, April 2020
  ,
 
I would ordinarily be sending wonderful Passover and Easter wishes to you and your families, but I imagine only a few people will be spending such celebrations as usual. While it may be different right now, we can all remember and be grateful for past celebrations and look forward to future ones - perhaps with a renewed appreciation. So, though it will no doubt be different this time - I wish each of you Happy Easter & Passover! Embrace the different and make it count!
 
It seems we are inundated with all things COVID-19, stories of friends, colleagues and relatives falling on hard times financially. Some of us are suffering the loss of persons who we love, or know. Some are sick and struggling. Many of us are filled with anxiety or worse. We are all adjusting to a big change in our day to day socialization, or lack thereof. Remember, we humans are resilient, we will get through.
 
It certainly is not business as usual, but we all have a role to play in helping support each other through these tough days.
 
The first day of spring happened a few weeks back and so we can look forward to warmer, longer, sunnier days which will help lift our positivity! As Robin Williams once said, " Spring is nature's way of saying, 'Let's party!'.  Wishing you all of the happiness of spring, the sounds of birds singing, the smell of flowers blossoming, and the renewal that comes with the change of season.
 
Before our May message, it will be Ramadan, so for those of you who celebrate, Ramadan Mubarak!
 
Enjoy the read,

Kim

P.S.  To pass the time, and have some fun we, present a contest of sorts.  No prizes, just pride!  With many of us working from home, our team has taken pictures of their home work stations and your challenge is to match the person with the station.  You can print and draw connecting lines or match the corresponding number to the letter.  Send completed answers to Shannon Hill, shannon@welpartners.com and we'll publish a list of those with a 100% score in our May Newsletter!  Have fun and stay safe. 




I. WEL NEWS
1. THE WALRUS, MARCH 2020
 
Kimberly Whaley was quoted in Sharon Riley's article, "Why Aren't We Free to Age on Our Own Terms?" The Walrus, March 18, 2020.
 
https://thewalrus.ca/why-arent-we-free-to-age-on-our-own-terms/
2. INVESTMENT EXECUTIVE, APRIL 2020

Matthew Rendely was quoted in an article by Rudy Mezzetta, "Digital Assets and Estate Planning" which was published on April 2, 2020.

3. WEL LAWYERS CHECKLIST: CHECKING FOR INDICATORS OF UNDUE INFLUENCE DURING VIRTUAL/DIGITAL (VIDEO) MEETINGS
 
On April 3, 2020 WEL Partners released our newest checklist:  Checking for Indicators of Undue Influence during Virtual/Digital (Video) Meetings

4. OSGOODE PROFESSIONAL DEVELOPMENT CPD PASSING OF ACCOUNTS & FIDUCIARY ACCOUNTING, April 7, 2020 

 
On April 7, 2020 Kimberly Whaley chaired the Osgoode CPD, Passing of Accounts & Fiduciary Accounting.  Professor Albert Oosterhoff presented on the topic of 'Compensation and Passing of Accounts' and Tracey Phinnemore presented on, 'Tips on Reviewing Accounts:  What Lawyers Need to Look for - Tips & Traps.' Ian Hull, Philippa Geddie, and Katherine Antonacopoulos also presented at this program.
 
 
5. WEL PARTNERS ON ELDER LAW
 
If you wish to receive a print copy please contact Blossom: blossom@welpartners.com.
 
You can download the pdf of this book:

 
Visit our website at http://welpartners.com/resources/publications to view our other published books .


II. SPECIAL NOTICES RE COVID-19 PANDEMIC
1.  EMERGENCY ORDER: PERMITTING VIRTUAL WITNESSING OF WILLS AND POWERS OF ATTORNEY

Please note that the Lieutenant Governor in Council has made an order under s. 7.0.2(4) of the Emergency Management and Civil Protection Act, providing that for the duration of the emergency:
  • a requirement under the Succession Law Reform Act that a testator or witness be present or in each other's presence for the making or acknowledgment of a signature on a will or for the subscribing of a will; and,
  • a requirement under the Substitute Decisions Act, that witnesses be present for the execution of a power of attorney,
may be satisfied by the means of audio-visual communication technology, provided that at least one person who is providing services as a witness is a Law Society of Ontario licensee at the time.

"audio-visual communication technology" means any electronic method of communication in which participants are able to see, hear and communicate with each other in real time.


The Order in Council will also be posted on this website:


and on e-Laws, as a regulation under the Emergency Management and Civil Protection Act at: 


2. WEL PARTNERS:  SPECIAL NOTICE - COVID-19 PANDEMIC AND CONTINUING WEL OPERATIONS

We are all facing unprecedented and challenging times during the COVID-19 Pandemic. The health and safety of our clients, staff, colleagues and the public is of utmost importance to us. Whaley Estate Litigation is continually monitoring the situation and is following all guidance from the Public Health Agency of Canada, Public Health Ontario, and Toronto Public Health.

We remain open and operating and continue to provide uninterrupted service for our clients and continue to intake new clients. We are taking all necessary measures to ensure our facilities are safe for firm members and clients and have in place remote work capabilities to accommodate our staff. All existing and potential WEL clients are invited to choose ZOOM technology to conduct client consultations and meetings. We are able to accept service via email.

We will continue to provide updates as the situation evolves. We wish you the best and rest assured we will get through this together.
3.  THE ONTARIO SECURITIES COMMISSION UPDATES

The Ontario Securities Commission (OSC) continues through the COVID-19 challenges presented, to identify and implement action to both detail impacts on operations as well as publish relief measures for market participants and notify respecting fraud warnings to investors.

All major Ontario Security Commission updates related to COVID-19 are found on the OSC website.
4.  NOTICE FROM THE CHIEF JUSTICE RE EXPANSION OF VIRTUAL COURTS, MARCH 27, 2020

5. NOTICE FROM THE MINISTRY OF THE ATTORNEY GENERAL'S COURT SERVICES DIVISION, MARCH 23, 2020
6.  CHANGES TO TORONTO REGION ESTATES LIST OPERATIONS IN LIGHT OF COVID-19, MARCH 23, 2020

7.  SCJ: ADVISORY NOTICE TO LAWYERS, LITIGANTS, WITNESSES, JURORS, MEDIA, AND MEMBERS OF THE PUBLIC REGARDING COVID-19, MARCH 13


III. WEL SHOUTOUTS
WEL Partners congratulates this year's recipients of the Law Society Medal, Professor Jeff Berryman, Marie Chen, Dr. Ron. Ellis, Arleen Huggins, Gilbert Labine, Colonel (Ret'd) Vihar Josh OMM, MSM, CD, QC, Heather Joy Ross, Dr. Dianne Saxe and Donald V. Thomson.

IV. LAW REVIEW
(i) BANK IMPROPERLY REFUSES TO ANSWER QUESTIONS REGARDING LAWSUIT ALLEGING BANKS OWE A DUTY OF CARE TO CUSTOMERS TO PREVENT ELDER FINANCIAL ABUSE
By Kimberly Whaley
 
An interesting lawsuit has been commenced in Alberta, where the plaintiff, an elderly woman, argues that the defendant bank owes a duty of care to its customers to help prevent fraud, particularly fraud against elderly customers. While the ultimate question of whether a bank owes such a duty of care has not been tried yet, this preliminary decision regarding a refusals and undertaking motion, Franiel v Toronto-Dominion Bank, 2020 ABQB 66, may be helpful in providing guidance on what are considered to be proper discovery questions in an elder financial abuse situation where a bank is named as a defendant.  
 
Background
 
The plaintiff is an 81-year-old customer of the Bank. Over a ten-month period in 2018, she was a victim of 26 fraudulent scams. On some occasions she believed she won the lottery, on other occasions she believed she owed money to the Canada Revenue Agency. None of these things were true; they were all scams perpetrated by fraudsters. After several bank drafts had been issued, the plaintiff's son visited a Bank branch, alerting the teller to the fact that he believed his mother may have been a victim of fraud. An electronic note was placed on the plaintiff's account. Despite this note, 12 more bank drafts were issued. Eventually, the plaintiff went to the Bank 26 times to obtain bank drafts, each just under $10,000.00 but in all totalled $241,730.00. The Bank was able to recover only $8,000.00 of her money.
 
The plaintiff sued the Bank arguing that an elderly customer, attending regularly for bank drafts for significant amounts of money, mostly just under $10,000.00, dealing face-to-face with bank tellers, should have raised "red flags" to the Bank and the Bank should have stepped in to stop her.
 
The Bank defends the claim on the basis that no such duty of care exists and even if there was, the Bank exercised reasonable oversight in the circumstances.
 
A questioning (called examinations for discovery in Ontario) was stopped early by the plaintiff's counsel on the basis that the questioning was "substantially frustrated by the number of improper objections and refusals to provide undertakings" by the Bank's counsel.  The plaintiff brought a motion to have the Bank answer the questions.
 
Questions Posed to the Bank Were Proper
 
Ultimately, Master Robertson concluded that most of the Bank's objections were not valid and most of the undertaking requests were proper requests. The plaintiff was entitled to re-commence questioning of the Bank's corporate representative.
 
What is interesting for the purposes of elder law considerations, and in the context of elder financial abuse, are the questions that were asked and deemed appropriate. Master Robertson noted:
 
The nature of the claim requires establishing that there actually is a duty of care owed by the Bank in these circumstances. That requires the plaintiff to demonstrate, or at least explore, such things as the Bank's knowledge of the sorts of fraudulent activities of which its customers generally are being victimized; when the Bank became aware (or should have become aware) of those sorts of fraudulent activities being perpetrated on [the plaintiff]; whether the fraudulent activity here appeared to the Bank's tellers to be frequent; whether the Bank adopted any practices, policies, practices [sic], or procedures in order to protect its customers against those fraudulent activities; what those policies, practices, or procedures were; whether they were being followed; and whether those policies, practices or procedures were actually communicated to the tellers on the "front line" of the Bank's interaction with its customers by formal training or otherwise. 
 
Master Robertson observed that the Bank's unstated position seemed to be that since it was confident it did not owe a duty of care at all "to see why a customer is withdrawing or investing her money and no duty to decline to act on the customer's instructions," it was not obliged to provide candid answers to questions as to the Bank's level of knowledge of these sorts of frauds generally, or its specific level of knowledge of the plaintiff's behaviour. This was an error.  There was no application to strike the claim or dismiss the claim. Importantly, the scope of questions which a party is entitled to ask is determined by the pleadings.
 
An example of one of the questions refused, but later ordered to be answered, was "Do you have knowledge as to why you hadn't seen a document produced by the Bank entitled "Protecting the Elderly from Fraud and Financial Abuse" published March 13, 2017, online?"  The document in question was a Bank blog post, and it specifically described "red flags" when dealing with elderly customers and specifically discussed "frequent large withdrawals of money in a short period of time, or unexplained liquidation of investments" and "conversations reveal unexpected lottery win, a new fiancĂ©, or other life changes."
 
Master Robertson found that the question about the document was appropriate and should be answered by the Bank representative, a Branch Manager. The document produced by the Bank seemed to have a significance to the claim and the Bank's defence, and the plaintiff's counsel was entitled to explore why it was that she, as a bank manager of a branch where some of the frauds were partly carried out, was not aware of it and why she, as the witness for the Bank, was unable to answer questions about it.
 
Takeaway
 
While the question of whether a bank owes a duty of care claimed by the plaintiff will have to be answered on another day, this case is interesting since it provides potential precedent for constructing  proper questions to be asked in cases of elder financial abuse perpetrated through bank drafts or other bank instruments. It also raises some interesting questions about whether our financial institutions have a role or responsibility in stopping or preventing financial abuse of older adult customers, and what that role or responsibility looks like. 
(ii) THE LIMITATION PERIOD TO COMMENCE A WILL CHALLENGE SEEKING SUBSTANTIVE AND CONSEQUENTIAL RELIEF
By Sareh Lua Ebrahimi
 
Bristol v. Bristol, 2020 ONSC 1684 (CanLII),  http://canlii.ca/t/j6079 
 
Introduction
 
In this motion to dismiss, brought by the Respondent (Berry), the Ontario Superior Court of Justice was asked to dismiss a Notice of Application (the "Application") as well as an ancillary Notice of Objection ("Objection") filed by the Applicant (Stephanie), on the grounds that the Application was statute-barred.
 
In arguing against the dismissal of the Application, the Applicant stated that the Objection and the accompanying Notice of Appearance were considered a "proceeding", which was filed within the limitation period. Alternatively, the Applicant argued that she was self-represented until April 2019 and did not understand that she needed to issue an Application to crystallize the complaints set out in her Objection.
 
Background
 
Elizabeth Bristol (the "Deceased"), passed away on December 6, 2016. The Deceased had ten children. The Applicant is the Deceased's daughter, and, the Respondent, the Deceased's son.
 
The Deceased had executed the following two wills, both prepared by a lawyer.
  1. The first will (referred to as the "2002 Will"), divided her estate equally between her ten children and named the Respondent as Estate Trustee.
     
  2. The second will (referred to as the "2004 Will"), named the Respondent as the Estate Trustee and the sole beneficiary of the Deceased's estate.
The Applicant filed an Objection on December 30, 2016, objecting to the issuance of a Certificate of Appointment of Estate Trustee to the Respondent on the grounds that the Deceased lacked testamentary mental capacity at the time she executed the 2004 Will; that the Deceased was unduly influenced by the Respondent, since the Deceased made a dramatic change to her will by leaving the residue of her estate to the Respondent alone; and, that the will makes no provision for dependants. The Objection was prepared by a Lawyer that the Applicant had consulted at the time.
 
Upon the Respondent filing the Application for Certificate of Appointment of Estate Trustee with a Will on January 29, 2017, the Registrar issued a Notice, that an Objection had been filed. The Applicant filed a Notice of Appearance on July 25, 2017. No further steps were taken by either party until the Applicant brought a Motion for Directions on April 23, 2019, seeking direction from the Court as to what steps she should take. The Court indicated that the Applicant should issue her Application within 45 days but without prejudice to the Respondent bringing a motion to dismiss on the grounds that the Application was statute-barred.
 
Issues and Analysis
 
There were a few issues that the Court had to consider and analyze.
 
In determining when the limitation period began to run, the Court reviewed the Limitations Act,[1] specifically sections 4 (dealing with the basic limitation period of two years) and, 5 (dealing with the discovery of a claim and the presumption that a person shall be assumed to have known of the claim on the day the act or omission on which the claim is based took place unless the contrary is proved).
 
The Court considered the case of Leibel v Leibel, where it was confirmed that a will speaks from the date of death and, as such, any proceeding must be taken within two years of the date of death, barring any discoverability issues.
[2]
 
There was no dispute that the Applicant knew of the contents of the 2004 will by at least December 7, 2016, and certainly by the date of filing the Objection on December 30, 2016.
 
In determining whether the discoverability principle would apply to delay the running of the two-year limitation period, the Court found that the Applicant knew of concerns related to undue influence and/or capacity as of December 30, 2016, when she filed the Objection since she had retained a lawyer to prepare same, and, she had received a copy of the will shortly after the date of death (or knew of its contents).
 
The Court stated that the Applicant's claims were "discoverable" as early as December 7, 2016, and as late as December 30, 2016, therefore she was in a position to move forward with her claims during the two-year limitation period.
 
The Court further stated "... [the Applicant] may view this interpretation "unfair" but, a strict approach to containing litigation must reasonably be what the Legislature intended when they changed the limitation period from six years to two years." [3]
 
In determining whether any of the steps taken by the Applicant before December 30, 2018, constituted a "Proceeding" within the meaning of the Limitation Act, the Court looked at rule 1.03 of the Rules of Civil Procedure, [4]
which defines a "proceeding" as either an action or application. An application includes a Notice of Application which would include a Notice of Application for Appointment of Estate Trustee with a Will.
 
The Court found that neither, the Objection filed on December 30, 2016, nor, the subsequent Notice of Appearance filed by the Applicant qualified as a "proceeding." It further stated that a Motion for Directions is not a "Proceeding" and cannot retroactively cure the Applicant's timing problem. Of note is that the Motion for Directions itself was brought outside the limitation period.
 
In determining whether the Application can stand due to its claims for declaratory relief, the Court found that this position is not justifiable, as the relief sought by the Applicant was truly substantive and consequential relief.
 
Takeaway
 
Importantly, the Court found that the Applicant cannot escape the consequences of sections 4 and 5 of the Limitations Act by framing her relief as declaratory. The motion to dismiss was granted.


[1] 2002, S.O. 2002, c. 24, Sch. B
[2] 2014 ONSC 4516, 2014 CarswellOnt 11102 at para 36
[3] Para 27 of Bristol
[4] Rules of Civil Procedure,  R.R.O. 1990, Regulation 194
(iii)  CAN A JOINT TENANCY BE SEVERED BEFORE DEATH, IF THE SEVERANCE IS ONLY REGISTERED AFTER?
By Henry Howe
 
Thompson v Elliott Estate , 2020 ONSC 1004 http://canlii.ca/t/j5rnj   
 
  A "zombie transfer" is a land transfer that is registered after the transferor's death, as if the transferor were still alive. The Land Registry Office generally rejects these transfers.
 
Thompson v Elliott Estate [1 is a recent case in which the court held that a severance of joint tenancy, which had become a "zombie transfer" due to a lawyer's errors, was valid nonetheless. The decision considers precisely when a severance of joint tenancy can be held to have taken effect, and discusses what a transferor's lawyer should do after having mistakenly delayed registration such that it has become posthumous.
 
Background
 
The deceased ("Elliott") had been married to the applicant ("Thompson") until her death. The couple had purchased their matrimonial home as joint tenants.
 
Elliott was hospitalized several months before her death, and stayed in the hospital for the remainder of her life. Approximately one month before her death, she contacted a lawyer, and indicated that she wished to make a new will. When the lawyer visited her, she explained that her marriage had broken down, and that in addition to a new will that disinherited Thompson, she also wished to sever the joint tenancy in their home. She had already made new Powers of Attorney in favour of her adult children.
 
When Elliott executed the will, she noticed that her name had been misspelled. The lawyer later sent two staff members to have Elliott sign a corrected will, as well as an Acknowledgement and Direction to transfer her stake in the home so as to sever the joint tenancy.
 
After Elliott's death, the lawyer discovered that, despite Elliott's instruction to register the land transfer, the document had instead been left in her will file by mistake. The lawyer promptly registered the transfer anyway, making inaccurate "law statements" as if Elliott were still alive. Had the lawyer not made these inaccurate statements, the transfer would have been rejected.
 
Thompson was not aware that Elliott had executed any of the above documents until after Elliott's death. He learned of the transfer when her estate trustees approached him to negotiate the sale of the home. The parties cooperated to sell the home, with the estate trustee's falsely reporting the date of Elliott's death so that it appeared to have occurred one day after the lawyer had registered the transfer. Thompson then commenced an application to determine his entitlement to the proceeds of the sale.
 
Elliott's capacity was not an issue in the proceedings.
 
Decision
 
MacLeod-Beliveau J., found that the severance of joint tenancy was valid, and that Thompson was entitled to a 50% interest in the proceeds of the property as a tenant in common. The severance had taken effect when Elliott had signed the Acknowledgement and Direction, and then delivered it to the lawyer, unconditionally and with the instruction that it be immediately registered. Thompson's application was dismissed.
 
"Delivery"
 
MacLeod-Beliveau J., rejected Thompson's argument that the severance of joint tenancy could only take effect when the transfer was registered. Instead, on review of the relevant caselaw and statutory provisions, she found that "[t]he law in Ontario... is settled and clear in that it is the delivery, and not the actual registration of the deed/transfer that determines if a joint tenancy has been severed."
 
With regard to what constitutes "delivery," MacLeod-Beliveau J. found that it was not merely the receipt by the lawyer of the signed Acknowledgement and Direction, but also Elliott's indication that she intended to be "immediately and unconditionally bound" by the transfer. Elliott's instructions had been clear, and although the lawyer had not immediately registered the transfer, Elliott's intention had been that the lawyer would do so.
 
Whether a transferor's actions constitute delivery is a question of fact, with the onus on the party seeking to uphold the purported severance? Elliott's estate trustees provided sufficient evidence of delivery, such that the joint tenancy was severed.
 
How to Resolve a Lawyer's Error
 
MacLeod-Beliveau J., helpfully noted that instead of registering the transfer after Elliott's death, and making inaccurate "law statements" in the process, the lawyer should have:
 
[brought] an application in the Superior Court of Ontario requesting a certificate of pending litigation and a declaration of an interest in land and for a vesting order under s. 100 of the Courts of Justice Act, setting out all the material facts in support of the inadvertence and the circumstances as to the delivery of the transfer, in an application to be determined by the court.
 
S. 25 of the Land Titles Act[2] compels the registrar to obey court orders in relation to registered land.


[1] 2020 ONSC 1004
[2] RSO 1990, c L.5

V. BOOK REVIEW
By Sareh Lua Ebrahimi
 
During one of my conversations with my mum, she told me about a book that she was reading and which I too , had to read since I would enjoy and appreciate it as much as she had, and she was absolutely right. With everything that is currently happening around us, I, as well as many others I'm sure are re-evaluating their priorities, purpose in life, relationships with people and trying to make sense of the current state of affairs and the reason behind it.
 
With Oars and Compass: A Purposeful Journey into Life, Love and Happiness by Hamed Javaheri (2019), very cleverly navigates through a personal story, the creation of which is itself positioned as a gift to a friend who accompanied the storyteller on a journey from an undirected, circumscribed, self-conscious, and self-focused (materially focused) life, to a life filled with joy, direction, and focus driven by the discovery of her essential purpose (one that we each have to discover).

The characters in the story - through their interaction - and the story itself allow the reader to learn the essence of the pathway to which we are called. They learn to walk the path of service, have meaningful conversations, to unify, to expand their circle of friends, to learn from each other and others not necessarily on the path - and all this in the dynamic affluent world of work, hesitant romance, and facing the past and the present. You will be longing for more as you read the last word. But you will think to yourself - well that just makes so much sense; I can do that. I know my essential purpose. I cannot put it off anymore.
 
It is an easy, delightful, all-too-soon-over must-read.

VI. UPCOMING EVENTS
Note: Due to the Covid-19 Pandemic many upcoming events are being cancelled, rescheduled or moved on-line.  Please check the event info links for the latest information from the event organizers.

Osgoode Professional Development - WEBINAR
The Osgoode Intensive Program in Wills and Estates
Powers of Attorney and Guardianship: Non-contentious and Contentious Matters
April 28, 2020
Speaker: Kimberly Whaley
 
Law Society of Ontario, The Six-Minute Estates Lawyer 2020
Raiders of the Lost Will, Proving Due Execution
NEW DATE TO BE PROVIDED     
Speaker: Kimberly Whaley
 
Ontario Bar Association, Elder Law Section Program
Your Comprehensive Guide to Section 3 Counsel Under the Substitute Decisions Act
NEW DATE TO BE PROVIDED
Chairs: Kimberly Whaley and Alex Procope
 
Toronto Police Seminar
Civil and Criminal Remedies, Elder Abuse
May 15, 2020 - DATE TO BE CONFIRMED
Speakers: Sareh Lua Ebrahimi and Henry Howe
 
Law Society of Ontario, 15th Solo and Small Firm Conference
The Solo/Small Advantage
NEW DATE TO BE CONFIRMED
Speaker: Kimberly Whaley
 
Ontario Bar Association Elder Law Passport Series Program
Capacity for Lawyers: Elder and Corporate Client Matters
June 17, 2020
Speaker: Kimberly Whaley
 
Law Society of Ontario, Practice Gems: Administration of Estates 2020
September 21, 2020
Chairs: Kimberly Whaley and Timothy Grieves
 
Toronto Police Seminar
Civil and Criminal Remedies, Elder Abuse
October 9, 2020
Speakers: Mike Marra and Matthew Rendely
 
Temple Emanu-El, 2020 Fall Lecture Series
Concepts of Ageism
October 5, 2020
Speakers: Kimberly Whaley and Sareh Lua Ebrahimi
 
1GTA Accountants Network
Trusts & Estates For Financial Professionals
October 20, 2020
Speakers: WEL firm members
 
Forum on Estate Planning and Litigation
November 11-13, 2020
Hotel William Gray in Montreal
 
STEP Global Special Interest Group (SIG) Annual Conference
Digital Assets
December 4, 2020
Speaker: Kimberly Whaley
 
Toronto Police Seminar
Civil and Criminal Remedies, Elder Abuse
December 11, 2020    
Speakers: Daniel Paperny and Bryan Gilmartin
 
International Federation of Ageing-15th Global Conference on Ageing
Niagara Falls, March 3-5, 2021 

VII. IN CASE YOU MISSED IT - RECENT BLOG POSTS
Expert's Letter of Engagement is Critical

Law Times: Equitable doctrine back before Ontario court after more than a century

Introducing Dr. Heyland and the Plan Well Guide

Mike Marra's Holiday Reads

Spouse vs Common Law Spouse - A Constitutional Question

Badges of Fraud

Dismissing for Delay - Rule 24.01 and Dismissal of Proceedings on the Basis of Inordinate Delay

Striking an Objection in Dessisa and Wolde v Demisie
 

Is it Time to Amend Section 4 of the Succession Law Reform Act?

Urgency Advocacy in Unprecedented Times

Modernizing the Law of Wills in Manitoba

VIII. MARKETING SERVICES & RECOMENDATION
Ken Raymond of rubbermustard communications, has been providing WEL Partners with comprehensive marketing services for over 10 years.  Ken designed and manages WEL's website & blog as well as our marketing communications, advertising, newsletter, brochures, stationary and business cards, promotional items, books, conference presence and more.  

If you want to reach out to Ken, he can be reached at:  kraymond@rubbermustard.com (416) 576-3650,  rubbermustard.com

IX. CONNECT WITH WEL
Do you follow us on social media? Do you subscribe to our blog?  We invite our subscribers to read our blog on-line or via a feed reader using our blog's RSS feed and to follow us on social media.
Newsletter Archive
Access past editions of the WEL Newsletter:  WEL Newsletter Archive
WEL Blog
Follow the WEL Blog:  http://welpartners.com/blog/

WEL Blog RSS Feed:  http://welpartners.com/blog/feed/
Online Connections
  Follow us on Twitter   View our profile on LinkedIn    




Sign Up for Our Mailing List
WEL Directory