Hello,
It is my hope with double vaccinations on the rise and businesses re-opening that you are starting to enjoy some return of routine and entertainment in your lives.
On a less serious note this month, take some down time and enjoy the summer.
Thank you for your continued support of our team. I acknowledge with gratitude that we have continued to do business during the pandemic because of you.
Stay Safe, Enjoy the Summer and the Read
Kim
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1. THE MORNING SHOW, JUNE 28, 2021 |
Our Daniel Paperny was a guest on the Morning Show with Devon Peacock on Global News Radio on Monday, June 28, 2021 to discuss the Britney Spears Conservatorship, and Guardianship in Ontario.
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2. OBA, TRUSTS & ESTATES LAW SECTION, HOFFSTEIN BOOK PRIZE, 2021 |
On June 24, 2021, Matthew Rendely was awarded the Hoffstein Book Prize.
The Hoffstein Book Prize was created to recognize contributions and/or achievements by younger members of the Ontario Bar Association to the area of wills, trusts and estates. Congratulations to our Matty!
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STEP PRIVATE CLIENT AWARDS 2021 |
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WEL congratulates the finalists for the 15th Annual STEP Private Client Awards. Well Done and Good Luck!
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WEL congratulates Bryan Gilmartin on being appointed as a Member-at-Large of both the ADR Section and the Elder Law Section of the OBA.
WEL congratulates Matthew Rendely on being appointed as the CPD Liaison of the OBA Elder Executive Section.
WEL congratulates Daniel Paperny on being appointed as a member of the OBA Sole Small Firm Section.
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(i) A STATUTORY DEVOLUTION OF THE OFFICE OF ADMINISTRATOR IN ONTARIO?
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By Albert H. Oosterhoff
Is devolution of the office of administrator possible in Ontario?[1] This may seem a strange question. It is clear that it is not possible at common law, but the common law is also clear that the rights and obligations of an executor can devolve upon her successor in certain circumstances. It means that, subject to certain conditions, when an executor dies, the responsibilities of the office are transmitted automatically to her executor. Devolution of executorship is described very well in the seminal Canadian text on Probate Practice.[2] The following are the preconditions before the doctrine can operate:
(a) The executor must have obtained probate of the will.[3]
(b) When the executor dies she has not yet completed administration of the estate.[4]
(c) The executor has not named a separate successor for the original estate.
(d) The executor’s executor must prove the first executor’s will.
I shall now describe how the doctrine operates with the aid of a couple of examples:
1. A appoints B as her executor in her will. B proves the will, but dies before completing the administration of the estate and names F as his executor in his will, F then becomes the executor of A’s estate by devolution of executorship when she proves B’s will. However, if B died intestate and G is appointed his administrator, there can be no devolution. The intestacy ‘breaks the chain’.
2. A appoints two or more executors, for example, B and C, and both prove A’s will, but C then dies and appoints an executor in his will. Later, B dies intestate. There can be no devolution to C’s executor, because the intestacy again ‘breaks the chain’.[5]
Thus, the administrator of an executor cannot succeed to the executorship.[6] Nor can the administrator of the estate of an administrator. Further, if the court appoints an executor of an estate, his executor does not succeed to the executorship of the original estate.[7]
But does the Trustee Act perhaps provide for a statutory devolution of the office of administrator? For this we need to look at the definitions and two very similar survivorship provisions in this Act.
Section 1 of the Trustee Act contains the following definitions:
“personal representative” means an executor, an administrator, and an administrator with the will annexed;
“trust” . . . extends to and includes the office of personal representative of a deceased person, and
“trustee” has a corresponding meaning and includes a trustee however appointed and several joint trustees.
Sections 3(2) and 46(2) provide:
3(2) Until the appointment of new trustees, the personal representatives or representative for the time being of a sole trustee, or where there were two or more trustees, of the last surviving or continuing trustee, are or is capable of exercising or performing any power or trust that was given to or capable of being exercised by the sole or last surviving trustee.
46(2) Until the appointment of new personal representatives, the personal representatives or representative for the time being of a sole personal representative, or, where there were two or more personal representatives, of the last surviving or continuing personal representative, may exercise or perform any power or trust that was given to, or capable of being exercised by the sole or last surviving personal representative.
Clearly, s. 46(2) is simply a copy of s. 3(2), the only change being the reference to ‘personal representative(s)’ instead of ‘trustee(s)’.
Before looking more closely at these provisions, it is clear from the definitions that the Trustee Act applies also, subject to some exceptions, to executors and administrators.[8] In my opinion this is regrettable, because it tends to confuse the two distinct offices of personal representatives and trustees. Some other trustee statutes do not apply to executors and administrators,[9] but instead deal with all issues concerning the administration of estates in separate legislation, where it belongs.[10] This does not mean that there is no overlap between the offices of personal representative and trustee. In many instances the principles that govern them, such as their succession, are very similar and although their offices remain distinct, many of their rights, duties, and powers can be assimilated as the Ontario Law Reform Commission recommended in its report on administration, although provision for the rights and obligations of the two office should be made in two separate statutes.[11] Of course, the Ontario Law Reform Commission’s reports on Trusts and Administration were never implemented and that was a great opportunity missed to modernize and rationalize the law applying to both offices. In consequence, Ontario is left with administration of estates legislation spread over several statutes, the Estates Act,[12] the Estates Administration Act,[13] and the Trustee Act,[14] which is regrettable. A convenient way in which the desired result could be achieved is to incorporate by reference provisions such as the appointment, retirement, removal and succession of trustees, contained in a revised Trustee Act, into a new Estate Administration Act. And the latter Act would rationalize the provisions of the current Act and the Estates Act.
Now I shall consider ss. 3(2) and 46(2) of the Trustee Act. First, arguably, there is no need for s. 46(2) at all. The definitions of ‘trust’ and ‘trustee’ in s. 1 of the Act mean that you can simply read either the word ‘executor(s), or ‘administrator(s)’, or both, or, for that matter the collective term, ‘personal representative(s)’ into s. 3(2) to replace the word ‘trustee(s)’. To keep it simple, I have inserted the collective term ‘personal representative(s)’ into s. 3(2). Thus the section will read (just like s. 46(2):
3(2) Until the appointment of new personal representatives, the personal representatives or personal representative for the time being of a sole personal representative, or where there were two or more personal representatives, of the last surviving or continuing personal representatives, are or is capable of exercising or performing any power or trust that was given to or capable of being exercised by the sole or last surviving personal representative.
The word ‘trust’ in the section when applied to personal representatives is somewhat strange, but it appears also in s. 46(2). In any event, arguably this does not refer to a true trust, but simply any fiduciary duty. As I have pointed out elsewhere, the word ‘trust’ is often used loosely and does not necessarily denote a relationship in which a trustee holds title to property for others.[15] Usually this does not cause any difficulty, but it can lead to misinterpretation and incorrect decisions.[16]
I believe therefore that section 3(2) provides for a statutory devolution of the office of executor and the office of administrator. So does s. 46(2) and, if thought necessary, one can rely on that section instead, though I believe it to be supererogatory. But in either case, in my opinion administration no longer breaks the chain of devolution.
It is true that both sections begin with the words, ‘Until the appointment of new …’ and that clearly means that a new administrator or executor can be appointed. But often that will not happen and cannot happen without an application to the court. By letting the personal representative of the deceased trustee, executor, or administrator assume the now vacant office to continue the administration of the trust or estate, you avoid the expense and delay of appointing someone new.
Of course this does not mean that the preconditions to devolution mentioned above have disappeared. However, they need to be revised to incorporate references to an administrator and to obtaining letters of administration.[17] Clearly, the preconditions could be incorporated into the legislation and probably should be. In addition, the provisions directed to the appointment, retirement, removal and succession of personal representatives, such as ss. 2(2), 37, and 46(2) of the Trustee Act, should be repealed when revising that Act. Instead, that Act should apply only to trustees. However, a new Estate Administration Act can then incorporate those provisions by reference.
When we then consider how the devolution of the office of administrator would work, we can apply the two examples used above, but somewhat modified, together with a third:
1. A appoints B as her executor in her will. B proves the will, but dies before completing the administration of the estate and names F as his executor in his will, F then becomes the executor of A’s estate by devolution of executorship when she proves B’s will.
Alternatively, assume that B died intestate and G is appointed his administrator. Then under ss. 3(2) or 46(2) the duties that B has not yet completed in A’s estate will be transmitted to G. The intestacy no longer ‘breaks the chain’.
2. A appoints two or more executors, for example, B and C, and both prove A’s will, but C then dies and appoints an executor in his will. Later, B dies intestate and H is appointed his administrator. Then the duties that B has not yet completed in A’s estate will be transmitted to H. The intestacy no longer ‘breaks the chain’.
3. The court appoints M as administrator in A’s estate. M appoints P as executor in her will, but dies before completing the administration of A’s estate. P can then succeed to the office of administrator in A’s estate.
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[1] My friend and colleague, Thomas Grozinger, posed this question to me and urged me to write a blog on it. I am indebted to him for raising the question and for sharing his ideas on the issue. I am also very grateful to Ian Hull for reading a draft of this blog and giving me his views on it.
[2] Macdonell, Sheard and Hull on Probate Practice, 5th ed. by Ian M. Hull and Suzana Popovic-Montag (Toronto: Thomson Reuters/Carswell, 2016), pp. 248-49. The description of the doctrine in this blog is based on this helpful text.
[3] Devolution is permitted only if the executor has proved the will. If he has not, the court must appoint an administrator of the original estate, ibid. p. 248; Estates Act, R.S.O. 1990, c. E.21, s. 25.
[4] If administration has been completed, there can be no devolution, Macdonell, p. 236. The executor has become a trustee once administration is complete (by virtue of an express or an implied assent), so her work as executor is done. See Albert H. Oosterhoff, ‘Locus of Title in an Unadministered Estate and the Law of Assent’ (2018), 48 Adv. Q. 44, §3. And see, e.g., Attenborough v. Solomon & Son, [1913] A.C. 76 (H.L.).
[6] But see s. 46(2) of the Trustee Act, R.S.O. 1990, c. T.26, to be discussed below.
[8] The exceptions are these: Section 2(1) of the Act permits trustees to retire in certain circumstances, but s. 2(2) provides that this section does not apply to executors or administrators. They can be removed only by order of the court under s. 37 of the Act.
[9] See, e.g., Trustee Act, R.S.B.C. 1996, c. 464, s. 1. See also An Act to Revise the Trustee Act, contained in the Ontario Law Reform Commission, Report on the Law of Trusts (Toronto, 1984), vol. II, s. 1(s), p. 487. And see Uniform Law Conference of Canada, Uniform Trustee Act (2012), https://ulcc-chlc.ca/ULCC/media/EN-Uniform-Acts/Uniform-Trustee-Act_1.pdf, although Part 6, ‘Trustee Compensation and Accounts’, does apply also to executors and administrators.
[10] See, e.g., Wills, Estates and Succession Act, S.B.C. 2009, c, 13, Part 6, Administration of Estates.
[11] Ontario Law Reform Commission, Report on Administration of Estates of Deceased Persons (Toronto, 1991), chapter 2.
[12] R.S.O. 1990, c. E.21.
[13] R.S.O. 1990, c. E.22.
[14] R.S.O. 1990, c. T.23.
[15] See Oosterhoff, ‘Locus of Title’, footnote XX [4], supra, §2,7, where I discuss the use of the word ‘trust’ in s. 2(1) of Ontario’s Estate Administration Act.
[16] See my blog, ‘Locus of Title in an Unadministered Estate Redux’, http://welpartners.com/blog/2020/02/locus-of-title-in-an-unadministered-estate-redux/, which is a comment on Boger Estate v. Minister of National Revenue, 1993 CarswellNat 930, 50 E.T.R. 1 (F.C.A.). A personal representative does not hold title to the estate assets in trust for the beneficiaries. She holds the full unbifurcated title to the assets until administration is complete. Only at that point does a true trust arise.
[17] Of course, if there is an administrator, he must perforce have been granted letters of administration.
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(ii) THINK YOU CAN HIDE BEHIND A SIGNATURE? THINK AGAIN! – BAYFORD V. BOESE, 2021 ONCA 442 |
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By Bryan Gilmartin
Bayford v. Boese,[1] a recent decision of the Court of Appeal, is a crucial reminder that a signature on a will is not always the answer. Rather, persons seeking to prove the validity of a will bear the onus of proving that it was executed in accordance with the formal requirements set out in section 4 (2) of the Succession Law Reform Act (SLRA):
Valid execution of a will
(2) Subject to subsection (3) and to sections 5 and 6, a will is not valid unless,
(a) at its end it is signed by the testator or by some other person in his or her presence and by his or her direction;
(b) the testator makes or acknowledges the signature in the presence of two or more attesting witnesses present at the same time; and
(c) two or more of the attesting witnesses subscribe the will in the presence of the testator.[2]
When the authenticity of a signature of a testator or witness is called into question, evidence must be adduced to overcome the burden of proving the formal validity of the will. As held by the Court of Appeal, relying on a signed copy of the will alone will not overcome this burden in the face of expert evidence indicating that the will was not executed in accordance with the formal requirements.
Facts
The deceased, Bruce Boese (the “Deceased”), was the owner of a farm. He never married and had no children. The Respondent, Brenda Bayford (“Brenda”), was a long-time friend of Bruce. She had assisted Bruce with the operation of the farm for the two decades before his death and described him as her best friend.
In 1992, Bruce executed a will (the “1992 Will”) which named his parents as the sole beneficiaries of his estate. Because they had pre-deceased Bruce, Bruce’s estate would pass on intestacy to his brother, Brian Boese (“Brian”), and the two daughters of his deceased sister Rhonda in the absence of a subsequent valid will.
In 2013, the Deceased worked with his long-time lawyer to prepare a will (the “2013 Will”). There were two versions of the 2013 Will. Version 1 was signed by the Deceased alone and version 2, was signed by the Deceased and two witnesses. Only copies of version 1 and version 2 were produced at trial (no originals).
Brian challenged the validity of the 2013 Will. He asserted that Brenda created version 2 along with the two witnesses after the Deceased’s death and after she discovered that version 1 was not validly executed. This was supported by the fact that version 1 of the 2013 Will was never produced at trial. Brian maintained that version 1 was the same document that became version 2 once witnessed in the weeks following the Deceased’s death.
Brenda’s evidence was that she ran into one of the witnesses who testified that they witnessed the Deceased sign the 2013 Will.
The central factual issue was whether version 2 had been signed by the witnesses before the deceased’s death, or afterward when Brenda noticed it needed to be witnessed to be valid. Version 2 was located prior to the hearing and Brenda filed a motion to introduce it as fresh evidence.
During trial, Brian produced evidence from a handwriting expert which indicated that the Deceased’s signature that appeared version 1 and version 2 of the 2013 Will were the same. Despite the expert’s findings, the trial judge declared that the 2013 Will was validly executed in accordance with section 4 of the SLRA. Brian appealed the decision.
Holding and Reason
The Appeal was allowed and it was held that the trial judge erred in finding that Brenda had discharged her burden to prove the formal validity of the 2013 Will. This was due to a misapprehension of the content and significance of expert evidence adduced at trial.
In particular, it was held that the trial judge made several palpable and overriding errors throughout the trial and did not appreciate the significance of expert evidence proffered by a handwriting expert who concluded that the Deceased’s signature on version 1 and version 2 were copies of one another.
Despite the expert’s findings, the trial judge declared that the 2013 Will had been validly executed in accordance with section 4 of the SLRA. The Court of Appeal held this to be a significant error as the expert’s evidence was central to the determination of whether the Deceased signed the 2013 Will before two attesting witnesses in accordance with the rules of formality for executing wills.
This evidence established that version 1 transformed into version 2 when the two witnesses signed the 2013 Will after the Deceased’s death, contrary to section 4(2) of the SLRA. Brenda did not rebut the expert’s findings at trial and therefore failed to meet her onus to prove the formal validity of version 2 of the 2013 Will.
Conclusion
This decision stands as a reminder that someone seeking to propound a will cannot use it as a shield against evidence that calls its validity into question. If there is evidence indicating that the will was not properly executed, the propounder must lead evidence to overcome such a finding and prove the formal validity of the will.
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[1] Bayford v. Boese, 2021 ONCA 442.
[2] Succession Law Reform Act, RSO 1990, c S.26, s. 4 (2).
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(iii) USING ENGLISH PROPERLY: MISUSE OF PERSONAL PRONOUNS |
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By Albert H. Oosterhoff
1. Introduction
I was very fortunate to have received an excellent grounding in English grammar and usage in high school. That was a long time ago, but it pains me, nay, irritates me, when people, often very well educated, misuse and abuse their native tongue. I am using ‘native’ in a broad sense here to mean either your mother tongue or your second language, but in either case it is the language that you use in your everyday communications. I am aware that grammar has not been taught in any depth in English Canadian schools for many years, so people who misuse the language have some excuse, but that goes only so far.
The legal profession is said to be a learned profession.[1] That imposes an obligation on all of us in the profession, who are or should be quintessential communicators, to use the language correctly. But you often get a very impression when lawyers and judges use illiterate expressions such as: ‘power of attorney’ for an ‘attorney’, ‘between you and I’, ‘go tell Mary and I’, ‘me and him are leaving’, and many others. When you use such expressions you give the impression that you are an ignoramus. Clearly, you don’t want people to think that of you. So what follows are some pointers about how you can avoid these egregious errors. And they are egregious, not mere footling mistakes.[2] Fortunately, they are not difficult to recognize and correct. And that is what this blog seeks to help you to do.
Please remember that the following examples illustrate the correct use of personal pronouns in formal writing. In everyday speech people do not always follow these rules strictly. When you are writing dialogue you also want to be true to your characters and so you may also not follow these rules. And that’s all right in both cases. But when you’re writing formally as professionals, you should follow the rules.
Before we can look at the errors, we need to have a quick look at some basic grammatical concepts (but for those of you who want to jump directly to the examples below, feel free to do so). The first is the concept of case. It indicates whether a noun or a pronoun is used as a subject or an object in a sentence. Modern English recognizes four cases: nominative, accusative, dative, and genitive. The terms derive from Latin grammar, so in English they are often referred to as the subjective, objective, and possessive cases, the objective being divided into direct and indirect objects. In this blog I shall focus only on the first three. Modern English as distinct from other languages, such as Latin, is not highly inflective, this is, it does not indicate which case is being used by different endings to nouns. We usually determine the case by placement of the word in a sentence. However, we do retain inflections in our pronouns; they change their form depending upon the case. And that is typically where the problems occur The pronouns that give us grief are the personal pronouns and the relative pronoun, who. In this blog I shall focus only on personal pronouns.
The personal pronouns for the first three cases are:
Nominative
Singular: I, you, he, she, it
Plural: we, you, they
Accusative
Singular: me, you, him, her, it
Plural: us, you, them
Dative
Singular: same as for the Accusative
Plural: same as for the Accusative
2. Examples
2.1 Personal Pronouns with Subject and Direct Object
The problems usually arise when a sentence contains a compound subject or object and one element of the compound is a pronoun. If it contains only a simple subject or object, you won’t normally have any difficulty in complying with the rules. For example, no one will say, ‘Me is going to the store’, or ‘Tell I when you’re done’. The first two of the following examples contain compound subjects and direct objects and illustrate how the problems typically arise.
1. Remember how you used to say when you were little, ‘Me and Sally are going to play’? And your mom would say, ‘No dear, you should say, “Sally and me are going to play; you should never name yourself first”’. Mom was both right and wrong. She was right to correct the error in etiquette, but she was wrong to condone the me. Why? Because me is in the objective or accusative case, but Sally and her friend are the compound subject, as is clear from the structure of the sentence. And so the sentence should read, ‘Sally and I are going to play’.
2. Suppose that you are addressing John and want him to remind Mary and you when the time for a project is up. So you say, ‘Be sure to call Mary and I when time’s up’. This is the reverse of example 1. The structure of the sentence tells you that Mary and I are the compound direct object. So I is wrong. You should have said, ‘Be sure to call Mary and me when time’s up’.
The same problems arise when both elements in the compound subject or object are pronouns. This is an example: ‘Me and her are going to win’. And here’s another: ‘Our colleagues were surprised when our boss let he and I go’. In the first example you need the subjective case, so it should read, ‘She and I are going to win’. In the second example you need the objective case, so the sentence should read, ‘Our colleagues were all surprised when our boss let him and me go’.
When a sentence contains compound subjects or objects and one member of the compound is a proper noun and the other is a pronoun, there’s an easy way to determine which pronoun is correct: delete the noun and change the verb to the singular. So in the first example, you would never say ‘Me is going to play’ right? So you know that the pronoun (and the verb) have to be ‘I am’ Similarly in the second example, you would never say, ‘Be sure to call I when time’s up’. So you know that the pronoun has to be in the objective case, i.e., me.
You can conduct a similar test when both elements of the compound are pronouns. Just delete one of the pronouns and change the verb. Then, using one of the above examples. ‘Me and her are going to win’, you get, ‘Me is going to win’. You know instinctively that this is wrong and thus both pronouns have be in the subjective case, she and I.
The same rules apply when a person uses the pronouns they and them. These usually stand for a plural noun, but they are often used in a singular sense. Thus, you might say, ‘Them will beat all the others’, or ‘Give that thing to they’. As in the previous examples, in the first instance them is the subject, so you should use they. In the second instance they is the direct object, so it should be them.
3. Well, that’s easy enough isn’t it? But now I’m going to throw you a curve ball. Mom has accused you and your sister of doing something wrong, but you were actually the culprit. Since you are contrite and morally upstanding, you confess and say, ‘No mom, it was me’. It looks as though me is a direct object of the verb form was. But was is a form of the copula or linking verb to be. Such a verb does not perform an action, but links the subject to the predicate. An alternative and more technical way to express that idea is to say that the pronoun me in the predicate completes the subject it and is thus known as a subject complement. That means that any pronouns that are linked to the verb ‘was’ have be in the subjective case. So the correct sentence is, ‘No mom, it was I’. I know, that sounds stuffy, but it is the format you should use in formal writing.
2.2 Personal Pronouns and the Indirect Object
A sentence can include both a direct and an indirect object, but it cannot have just an indirect object. When you have both, the verb in the sentence will tell you what it is doing to or about the object and it will also tell you to or for whom it is doing it. Thus, for example, in this sentence, ‘I gave him a piece of my mind’, the direct object is the phrase ‘piece of my mind’, for it is what you gave him. The indirect object is ‘him’. You can test that by asking who the recipient of the action is.
There are two ways of expressing the dative or indirect object: 1. by placing the noun or pronoun between the verb and the direct object, as in the example just given; or 2. by introducing the indirect object by the preposition ‘to’ or ‘for’. Thus, we could have phrased the example as follows, ‘I gave a piece of my mind to him. That is not how we would not normally express that thought, because it sounds stuffy. But you can see that in this case to dative follows the accusative.
An example of the ‘to’ form of the indirect object that sounds more natural is, ‘He gave a dozen long-stemmed red roses to his wife on Valentines Day’. Another way to think of the second form of the indirect object is to regard the noun or pronoun that follows ‘to’ or ‘for’ as the object of either of those prepositions. The examples I have just used indicate clearly that the pronoun must be in the objective case. But now let’s look at an example that illustrates where people often fail to follow that rule.
4. James asks Hilary, ‘When you’ve read the article, please return it to Tom and I’. The direct object has to be it, because that’s what Hilary is to return. So the indirect object must be the compound object Tom and I. Since it should be in the objective case, I is clearly wrong. It should be me. You can also test this result by taking out the proper noun Tom plus and. The sentence would then read. ‘When you’ve read the article, please return it to I. Since you would never say that, you know that I has to be wrong.
3. Conclusion
All right, that’s enough for now. Next time I shall write about the relative pronouns who and whom and some other grammatical issues.
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[1] Inc. Council of Law Reporting for England & Wales v. Attorney General, [1972] Ch. 73 (C.A.), at p. 72 per Sachs L.J., and at p. 101 per Buckley L.J.
[2] For those who want to learn more about English grammar and usage but are not grammar scholars, there are many resources available on the internet, such as grammar-monster.com and grammarbook.com. The latter also publishes a helpful book, The Blue Book of Grammar and Punctuation, by Lester Kaufman and Jane Straus. Other resources are available in book form. Some of them are geared to teaching English as a second language, but others are intended for a broader audience. Most are written in a breezy, easily accessible style with plenty of examples. The following as a few helpful texts: A Practical English Grammar, by A.J. Thomson and A.V. Martinet; The McGraw-Hill Handbook of English Grammar and Usage, by Mark Lester and Larry Beason; and The Joy of Syntax by June Casagrande. However, in my opinion, the Barnes & Noble Outline text entitled English Grammar, by George O. Curme, provides the most detailed and perspicacious treatment of the topic. The book was published in 1947 and is still available on Amazon.
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Toronto Police
Elder Abuse Investigator’s Course
Civil & Criminal Remedies
September 3, 2021
Speakers: Matthew Rendely and Bryan Gilmartin
LSO Administration of Estates
Limitation Periods and Advising Executors
September 23, 2021
Speaker: Daniel Paperny
International Federation of Ageing – 15th Global Conference on Ageing November 9-12, 2021
Speakers: Daniel Paperny and Matthew Rendely
Ontario Police
Elder Abuse Investigations 2021
November 16, 2021
Speakers: Bryan Gilmartin and Paul Murphy
LESA 53rd Annual Refresher: Managing Wills & Estates Matters
DATE: TBD
Decisional Capacity: A Wills & Estates Context
Speaker: Kimberly Whaley and John Poyser
Estate Planning and Litigation Forum
Spring 2022
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