Whaley Estate Litigation

Whaley Estate Litigation Newsletter No. 6 September 2011


 

Greetings!   

  

From our team at WEL we hope that you enjoyed a lovely summer and we hope you enjoy our 6th Newsletter.

 

Thank you to all of our readers for the very positive comments and feedback that we continue to receive.  We appreciate your interaction as we continue to develop our newsletter and new blog site. Please direct your feedback, comments or inquiries to:  
newsletter@whaleyestatelitigation.com.

 

Whaley Estate Litigation is pleased to provide legal services to you, or to your client in the following areas:

  • Will, Estate, Trust Challenges/Interpretations
  • Dependant Support Claims
  • Passing of Estate and Attorney Accounts
  • Capacity Proceedings
  • Guardianships
  • Power of Attorney Disputes
  • Consent and Capacity Board Hearings
  • End of Life Decisions
  • Treatment Disputes
  • Elder Law
  • Solicitor's Negligence
  • Opinions
  • Agency Services
Sincerely,

 

Kimberly A. Whaley
Whaley Estate Litigation


The Disposal of Human Remains - Who Decides in Ontario? 

 

Several times a year in my practice there is a family dispute over the disposal of a deceased person's body.  These disputes often end up before our Courts with the family asking a Judge to make a decision in order to resolve the dispute. The disputes can be anything from determining who has authority over the body, to how the body is disposed of, who has custody of the remains, the burial, authority to bury, the funeral, interment, disinterment, requests for DNA testing of remains, funeral homes seeking or compelling burial orders, religious considerations and so on.  Accordingly, developments in this area are important to many as are the basic legal principles upon which a Court has jurisdiction to make a decision.

 

In summary, it is the Estate Trustee (note: Executor, Estate Trustee, Administrator, and Personal Representative are all interchangeable terms used to reference the person who has been appointed by the Last Will and Testament, or the Court as the person, or entity responsible for administering the Estate of the Deceased), who determines the disposition of a Deceased's body.  The basic principles of our law as it exists in Ontario can be summarized as follows:

 

  1. The Estate Trustee of the Deceased's Estate has the right of possession of the body for the purpose of disposing of it. If there is no appointed Estate Trustee, the person(s) entitled to apply to be the Estate Trustee, has the right to possession of the body for burial purposes.  Section 29 of the Estates Act, R.S.O. 1990, c. E.21, enumerates  who is entitled to become the Deceased's Estate Trustee, where there is no appointment.   
  2. The Estate Trustee is duty bound to dispose of a body in a "dignified manner." Both burial and cremation are sanctioned methods of disposal.  The wishes of the Deceased concerning disposal are not binding on the Estate Trustee. As well, the Estate Trustee must not act capriciously.  
  3. An Estate Trustee must dispose of the body in a manner befitting of the Deceased's station in life.  
  4. The Estate Trustee has a strict duty to provide the particulars of the Deceased's burial to the next-of-kin.  
  5. Exceptions to the Estate Trustee's right of possession of the body include:

(a) where the Deceased consented to post-mortem donations;   

(b) where a warrant has been issued by the coroner; or   

(c) where disinterment has been ordered.

 

The duty to bury a corpse lies with the Deceased's Estate Trustee. This duty is protected by our criminal code.  Section 182 states:

 

182.   Everyone who

 

(a) neglects, without lawful excuse, to perform any duty that is imposed on him by law or that he undertakes with reference to the burial of a dead human body or human remains, or

 

(b) improperly or indecently interferes with or offers any indignity to a dead human body or human remains, whether buried or not,

 

is guilty of an indictable offence and liable to imprisonment for a term not exceeding five years.

 

Since there can be no 'property' in a human corpse, how does the Estate Trustee become responsible for disposing of the remains of the Deceased?  To learn the answer to this question and more about who decides how remains will be disposed of; whether the wishes, or the religion of the Deceased play a role in the disposal of remains; whether there is property in a human corpse, or in its body parts, or in its DNA, please access the following link to a paper written by me, entitled: "The Body, Ashes and Exhumation - Who Has The Last Word?"

 

Recent Legal Developments Concerning Burial Issues and Interment Rights:

 

In Ontario, the Funeral, Burial and Cremation Services Act, 2002, S.O. 2002, c.33 with written sections proclaimed not to come into force and effect until July 1, 2012, and applicable sections in effect already, is a law that was approved by the Ontario Legislature on December 13, 2002.  This Act consolidates and updates two existing pieces of legislation, the Funeral Directors and Establishment Act, RSO 1990, F.36 and the Cemeteries Act (Revised) R.S.O. 1990, Chapter C.4.

 

In Ontario, the Estate Trustee's right of possession of the Deceased's body remains and continues after burial.  It is important to know that the rights of an interment right's holder override the Estate Trustee's right to possession of the Deceased's body.  The relevant provisions in the legislation applicable to the interment right's holder, can be found in the Funeral Burial Cremation Services Act, 2002, with relevant sections, in effect currently.

 

Disinterment must occur in accordance with each Province's applicable legislation.  In Ontario, the Cemeteries Act (Revised) R.S.O. 1990, provides for the requirements of a disinterment, and the interment rights holder as follows:

 

Section 51(1):

 

Subject to subsection (2) no person shall disinter any human remains without, (a) the prior consent of the interment right's holder; and (b) notifying the proper medical officer of health for Ontario.

 

Section 161. (1) reads as follows:

 

Interment and scattering:

 

161.  (1)  No cemetery operator shall inter human remains in a lot, other than the remains of the interment rights holder, without the written consent of the interment rights holder. O. Reg. 30/11, s. 161 (1).

 

(2)  No cemetery operator shall scatter cremated human remains in a scattering ground, other than the remains of the scattering rights holder, without the written consent of the scattering rights holder. O. Reg. 30/11, s. 161 (2).

 

(3)  No cemetery operator shall,

(a) sell or provide interment or scattering rights for a limited term, or offer to do so;

(b) inter or permit the interment of humans remains for a limited term, or offer to do so; or

(c) scatter or permit the scattering of cremated human remains for a limited term, or offer to do so. O. Reg. 30/11, s. 161 (3).

 

(4)  A burial permit under the Vital Statistics Act is not required for the interment of products of conception that do not constitute a still-birth under that Act and for which no burial permit under that Act is therefore required to be issued. O. Reg. 30/11, s. 161 (4).

 

Disinterment and removal of human remains

 

162.  (1)  No person shall disinter human remains except in accordance with the Act and one of the following: this section, section 178 or 179 or a site disposition agreement mentioned in section 184. O. Reg. 30/11, s. 162 (1).

 

(2)  No person shall remove scattered cremated remains from a scattering ground except in accordance with this section. O. Reg. 30/11, s. 162 (2).

 

(3)  No person shall disinter any human remains unless,

(a) the prior consent of the interment rights holder has been obtained; and

(b) except if the remains are cremated human remains, prior notification has been given to the medical officer of health. O. Reg. 30/11, s. 162 (3).

 

(4)  No person shall remove scattered remains without the prior consent of the scattering rights holder. O. Reg. 30/11, s. 162 (4).

 

(5)  Subsections (3) and (4) do not apply to a disinterment or removal that is,

(a) made pursuant to a direction under section 102.1 of the Act; or

(b) ordered by the registrar under subsection 88 (7) of the Act pursuant to a cemetery closure. O. Reg. 30/11, s. 162 (5).

 

(6)  The registrar may consent under subsection (3) or (4) in the place of the interment or scattering rights holder if,

(a) the whereabouts of an interment or scattering rights holder are not known;

(b) the interment or scattering rights holder is not readily ascertainable; or

(c) the interment or scattering rights holder is not able to consent. O. Reg. 30/11, s. 162 (6).

 

(7)  Before consenting under subsection (6), the registrar shall consider whether any known person may have an interest in the disposition of the remains, and if there is such an interested person, shall order that the person proposing to do the disinterment or removal give notice of it to the interested person in the form and manner that the registrar specifies. O. Reg. 30/11, s. 162 (7).

 

(8)  If a person requests the consent of the registrar under subsection (6), a person who objects to the disinterment or removal may file a written objection, with reasons, with the registrar, at any time before the registrar consents to the disinterment or removal. O. Reg. 30/11, s. 162 (8).

 

(10)  Before consenting to a disinterment or removal, the registrar shall take into account the reasons for objecting that a person with an interest in the remains has. O. Reg. 30/11, s. 162 (10).

 

(11)  The registrar's consent to a disinterment or removal may be subject to the terms and conditions that the registrar considers appropriate. O. Reg. 30/11, s. 162 (11).

 

(12)  The registrar shall give notice of the registrar's decision to,

(a) the person requesting the registrar's consent,

(b) any interested person who was given notice under subsection (7);

(c) any person filing an objection under subsection (8); and

(d) the cemetery operator. O. Reg. 30/11, s. 162 (12).

 

(13)  A person receiving notice of the registrar's decision under subsection (12) may appeal the decision to the Tribunal by mailing or delivering, within 15 days after being served with the decision, a written request for a hearing to the registrar and to the Tribunal. O. Reg. 30/11, s. 162 (13).

 

(14)  If a person appeals the registrar's decision, the Tribunal shall hold a hearing and may uphold the registrar's decision or substitute its decision for that of the registrar. O. Reg. 30/11, s. 162 (14).

 

(15)  The registrar's decision to consent to disinterment or removal shall not take effect until,

(a) the time for appealing the decision has expired; or

(b) if an appeal is brought, the Tribunal has made an order upholding the registrar's decision to consent to the disinterment or removal. O. Reg. 30/11, s. 162 (15).

 

(16)  A medical officer of health may attend at, supervise or direct a disinterment or removal. O. Reg. 30/11, s. 162 (16).

 

(17)  If a medical officer of health determines that remains are those of a person who died of a communicable disease within the meaning of the Health Protection and Promotion Act, the remains shall be dealt with in accordance with that Act. O. Reg. 30/11, s. 162 (17).

 

(18)  No person shall remove a dead human body from a cemetery unless a certificate of a medical officer of health or the cemetery operator has been obtained and affixed to the container holding the body, confirming that the Act and the regulations have been complied with. O. Reg. 30/11, s. 162 (18).

 

(19)  A burial permit under the Vital Statistics Act is not required for the reinterment of a dead human body that has been disinterred in accordance with the Act and the regulations. O. Reg. 30/11, s. 162 (19).

 

(20)  Nothing in this section shall prohibit a cemetery operator from removing human remains placed in a cemetery without permission of the cemetery operator if the removal is authorized by the cemetery by-laws and if the removal is done in accordance with the cemetery by-laws.

 

Interment and scattering rights certificates

 

163.  (1)  A certificate of interment or scattering rights shall include,

(a) the name and location of the cemetery in which the interment or scattering is to take place;

(b) the name of the interment or scattering rights holder;

(c) the location and dimensions of the lot or scattering ground to which the interment or scattering rights relate;

(d) the date on which the interment or scattering rights are purchased or transferred, as the case may be;

(e) the amount paid by the purchaser for the interment or scattering rights;

(f) the amount deposited into the care and maintenance fund or account for the interment or scattering rights;

(g) a statement that, if the interment or scattering rights holder resells or transfers the interment or scattering rights, the endorsed certificate must be returned to the operator before the operator is required to issue a new certificate;

(h) in a conspicuous manner on the certificate, a statement whether any restrictions or obligations exist with respect to the installation of markers and if so, a statement of what they are or a reference to the by-laws containing them;

(i) if the interment rights are in a private structure, the total number of niches, crypts or compartments in the structure; and

(j) if the scattering rights are in a private scattering ground, the total number of scatterings permitted in the scattering ground, including whether the number is unlimited. O. Reg. 30/11, s. 163 (1).

 

(2)  A cemetery operator shall issue a new certificate of interment or scattering rights to a new holder of the rights after the cemetery operator has received the endorsed certificate under subsection 115 (3). O. Reg. 30/11, s. 163 (2).

 

(3)  A cemetery operator may charge a reasonable fee to recover the cost of issuing the new certificate. O. Reg. 30/11, s. 163 (3).

 

Case Law

 

In the case of Heafey v McRae,<1> the Ontario Court of Appeal judgment <2> affirming the original judgment and the proposition that the Estate Trustee's right to possession of the Deceased's body is superseded by the rights of the interment right's holder pursuant to the Cemeteries Act (Revised).<3>

 

Lajhner v Banoub <4>

 

This fairly recent case is a decision of the Ontario Superior Court of Justice, the Honourable Justice D. Gunsolus J., which case stands for the proposition that section 29(1) of the Estates Act <5>, does not, as in fact often contended, provide spouses, or those living in a conjugal relationship with the Deceased at the time of death, any priority to the appointment [of the Estate Trustee] over the next-of-kin of a Deceased person. This is important since S. 29 is often interpreted such that it reads as a hierarchal appointment scheme.

 

To what persons administration shall be granted

 

29.  (1)  Subject to subsection (3), where a person dies intestate or the executor named in the will refuses to prove the will, administration of the property of the deceased may be committed by the Superior Court of Justice to,

(a) the person to whom the deceased was married immediately before the death of the deceased or person with whom the deceased was living in a conjugal relationship outside marriage immediately before the death;

(b) the next of kin of the deceased; or

(c) the person mentioned in clause (a) and the next of kin,

 

as in the discretion of the court seems best, and, where more persons than one claim the administration as next of kin who are equal in degree of kindred to the deceased, or where only one desires the administration as next of kin where there are more persons than one of equal kindred, the administration may be committed to such one or more of such next of kin as the court thinks fit. R.S.O. 1990, c. E.21, s. 29 (1); 1999, c. 6, s. 23; 2005, c. 5, s. 24; 2006, c. 19, Sched. C, s. 1 (1).

 

Appointment at request of parties interested

 

(2)  Subject to subsection (3), where a person dies wholly intestate as to his or her property, or leaving a will affecting property but without having appointed an executor thereof, or an executor willing and competent to take probate and the persons entitled to administration, or a majority of such of them as are resident in Ontario, request that another person be appointed to be the administrator of the property of the deceased, or of any part of it, the right that such persons possessed to have administration granted to them in respect of it belongs to such person. R.S.O. 1990, c. E.21, s. 29 (2).

 

General power as to appointment of administrator under special circumstances

 

(3)  Where a person dies wholly intestate as to his or her property, or leaving a will affecting property but without having appointed an executor thereof willing and competent to take probate, or where the executor was at the time of the death of such person resident out of Ontario, and it appears to the court to be necessary or convenient by reason of the insolvency of the estate of the deceased, or other special circumstances, to appoint some person to be the administrator of the property of the deceased, or of any part of such property, other than the person who if this subsection had not been enacted would have been entitled to the grant of administration, it is not obligatory upon the court to grant administration to the person who if this subsection had not been enacted would have been entitled to a grant thereof, but the court may appoint such person as it thinks fit upon his or her giving such security as it may direct, and every such administration may be limited as it thinks fit. R.S.O. 1990, c. E.21, s. 29 (3).

 

Appointment of trust corporation

 

(4)  A trust corporation may be appointed as administrator under subsection (2) or (3), either alone or jointly with another person.

 

Justice Gunsolus states at paragraph 18 of the judgment :

 

"that a priority scheme would fetter or be a constraint upon the court's role and would detract from the court's parens patriae jurisdiction.  Moreover, the judgment clearly indicates that section 29(3) permits the court to have the ultimate discretion to appoint the executor when a person dies intestate".

 

Buswa v Canzoneri, 2010 ONSC 7137

 

For further recent case law on whether an Estate Trustee During Litigation may dispose of a Deceased's remains, please read our blog posting: Can the Estate Trustee During Litigation Dispose of the Deceased's Remains

 


1. Heafey v McRae (1991) CarswellOnt 5263 (Ont. S.C.J.)

2. Heafey v McRae, 2000 CarswellOnt 4415, 5 E.T.R. (3d) 125 (ONCA)

3. Cemeteries Act (Revised)  R.S.O. 1990, Chapter C.4

4. Lajhner v Banoub 2009 CarswellOnt 1745, 49 E.T.R. (3d) 87

5. The Estates Act, R.S.O. 1990, Chapter E. 21, Section 29

Environmentally Friendly Alternatives to Traditional Funeral, Burial and Cremation Services

 

Resomation®: What is it?

 

Resomation Ltd. was formed in Scotland in early 2007 to promote Resomation as an alternative to burial and cremation. The founder and managing director of Resomation Ltd., is Sandy Sullivan. The process is similar to that of cremation until the point at which the coffin is placed in a special pressure chamber, but instead of fire, Resomation uses a water and alkali based method to reduce the body down to basic elements. Once the process is complete, the liquid is drained and a pure white powder, similar to cremation ashes can be placed in an urn, or otherwise dealt with as authorized by the governing legislation.

 

Resomation is being described as the eco-friendly alternative to cremation.

 

The technology behind the Resomation process has been established for many years, in other words, a process of alkaline hydrolysis, which is the process for the disposal of human remains, whereby a body is placed in a silk bag, itself placed within a metal cage frame. The bag is then loaded into a Resomator. The machine is filled with a mixture of water and lye, and heated to a temperature around 160° C, at a high pressure, which prevents boiling.  The body is then broken down into its chemical components and the process is said to take in or about three hours.  When the process has been concluded, what remains is a green-brown tinted liquid. Resomation Ltd., has utilized the technology to develop a commercial alternative to cremation and burial.  Resomation Ltd.,  has been developing this process since in or about 2007 working closely with the Mayo Clinic in Minnesota, and in partnership with LBBC Technology in Leeds, United Kingdom. For more information on Resomation:  www.resomation.com and www.funeralinspirations.co.uk. These websites have literature explaining in detail the Resomation, also known as the bio-cremation process and what is involved.

 

In Canada, Transition Science Incorporated, whose website can be accessed at: www.transitionscience.com is a licensed distributor of Resomation in Canada. I contacted Allen Bessel, President of Transition Sciences Inc., who kindly assisted me in my research on Resomation, and informed me of the following:

 

Allen Bessel will offer the first bio-cremation system in Toronto. Transition Science Inc., has been working together with the legislature and the Province such that bio-cremation can be lawfully introduced as an environmentally friendly alternative to burial and cremation, and as a dignified and respectful means of disposing of human remains. The Funeral, Burial and Cremation and Services Act, 2002, is to fully come into force July 1, 2012. "Crematorium", which means a building fitted with appliances for the purposes of cremating human remains, and includes everything incidental and ancillary thereto, pursuant to the Cemeteries Act, (Revised) R.S.O. 1990, and to the Funeral, Burial and Cremation Services Act, would encompass bio-cremation, hence, it would as I understand, be authorized by the legislation about to come into force on July 1, 2012.

 

Allen Bessel, President of Transition Science Inc., can be contacted at: abessel@transitionscience.com

 

The benefits of Resomation, in addition to providing consumers with more choice in deciding how to dispose of a Deceased's remains, is said to have environmental benefits including reduction of emissions of greenhouse gases, a reduction of energy requirements, for instance compared to that of cremation, and easing the pressure of burial space, increasingly in short supply.

 

The Resomation process requires approval in each country within which the process is offered.

 

Cryomation®  www.cryomation.co.uk: What is it?

 

The process itself uses liquid nitrogen to freeze the body to 196°C. The body becomes brittle once frozen. The body is then fragmented, foreign metal objects removed, and body materials returned to the process. The remains are then freeze dried under a range of vacuumed conditions to remove moisture.  The process according to the website link referenced herein, states that a patent is pending and ensures that the final powder is sterile and 100 percent free of bacteria and viruses. 

 

Again, the benefits include space-saving, reduction in mercury emissions, and is said to result in a sterile and safe product suitable for green burial sites. 

  

Promession®: www.promession.org.uk:  What is it?

 

Promession is said to be another environmentally friendly option for disposal and burial.  Promession is a process which through freezing and vibration, breaks down human remains into a fine powder, with no release of toxins into the air or high energy use usually associated with cremation. 

 

The process is described in the linked website referenced above.  The process was developed in Sweden by a biologist, Susanne Wiigh-Mäsak.

  

Natural Burial also referred to as Woodland Burial, or Green Burial: What is it?

 

General principles of this kind of burial include the body not being embalmed with chemicals, but rather buried in bio degradable materials, for instance cardboard, bamboo, seagrass, willow or sustainable wood. A GPS co-ordinate, or scanable micro-chip can then be used to identify the burial site. In Ontario, there is a natural burial site at Cobourg Union Cemetery: www.ecoburials.ca

 

The website: www.novaterium.com presents a worldwide directory of green burial sites and funeral information.

 

 

Tax Tips: Post-Mortem Planning: Pipeline Strategy

 

By Brian Wilson, a tax lawyer, and our mediation partner at estatemediators.ca.

There are a number of planning opportunities that can be considered by the Estate Trustee to maximize the value of the Estate-including simply minimizing payment of tax on death. The most basic concept of post-mortem planning is looking for ways to mitigate tax payable on death.

 One technique is to use what is referred to as The "Pipeline Strategy". It attempts to avoid the impact of double taxation on an Estate where the deceased owns shares in a corporation, and those shares are left to certain beneficiaries. The deceased is deemed to have disposed of the shares at fair market value immediately prior to death and therefore is taxed on the accrued capital gain. Tax consequences are also triggered by an eventual sale of the corporation's underlying assets, or by the beneficiary's distribution of the corporation's assets to himself or herself.

 

Essentially, the "Pipeline Strategy" works as follows. For example, Mr. A dies owning shares of OPCO with a fair market value of $1,000,000, a nominal paid- up capital and a nominal cost base. The deemed disposition results in a capital gain of $1,000,000. The shares of OPCO now have a fair market value equal to their cost base. Assume there is $1,000,000 cash in OPCO. The estate transfers the shares of OPCO to Holdco in exchange for a promissory note for $1,000,000. OPCO then distributes the $1,000,000 cash to Holdco as a tax-free inter corporate dividend. Holdco then transfers the $1,000,000 to the estate in exchange for the cancellation of the note. Since the cost base and the fair market value of the note are both $1,000,000 there is no tax arising on this transaction.

 

There are a number of technical provisions in the Income Tax Act that can thwart the use of the "Pipeline Strategy" that a tax professional would review prior to recommending this strategy.

Follow Our Blog via RSS Feed 

We continually add articles and posts to our blog and will post update notices via Twitter and on LinkedIn.  If you would like to follow blog via our RSS feeds here is the link: 

http://whaleyestatelitigation.com/blog/feed/rss/ 

Upcoming Programs

 

2011 McMaster University-Fall Symposium-Taboo Topics: Time to Take Charge: Addressing Difficult Issues in Later Life: "Bad Decisions or Bad Decision-Makers? When Families and Health Practitioners Disagree"

September 21, 2011

Mark Handelman, Speaker

More info

 

STEP Seminar: Mistakes and Rectification, Taxes, Wills, Estates-75(2) Tainted Spousal Trusts in Trust and Estate Context

September  22, 2011

Kimberly A. Whaley, Chair

More info

 

CTF Seminar: Ontario Tax Conference 2011 - Keeping Tax Practitioners Informed. "Estate Planning: Litigation arising out of Estate Planning"

October  24, 2011

Kimberly A. Whaley, Speaker

More info

 

OBA Section Executive Program on Elder Abuse and the Estate Lawyer

October 26, 2011

Ameena Sultan, Chair

More info

 

LSUC: The Administration of Estates

October 31, 2011

Kimberly A. Whaley, Chair

More info

 

LSUC Summit : Solicitor and Client Assessments

November 9 and 10, 2011

Kimberly A. Whaley, Speaker

More info

 

OBA "Trusts and Estates: The Nuts and Bolts of Bonding"

November 29, 2011

Amy Cull, Case Presenter

More info

 

OBA Institute: Capacity to Marry, Divorce, and Separate

February 9, 2012,

Kimberly A. Whaley, Speaker

 

LSUC, Six-Minute Lawyer: Topic TBA

April 24, 2012

Kimberly A. Whaley, Speaker

 

NAELA and the CBA Elder Law Executive in partnership, Seattle Elder Law Conference: Topic - TBA

April 26-28, 2012,

Kimberly A. Whaley, Speaker

More info

 

CLC CBA Vancouver, Blended Family Presentation: Topic - TBA

August 12-14, 2012,

Kimberly A. Whaley, Speaker

 

LSUC: The Administration of Estates 2012

September 13, 2012

Chair, Kimberly A. Whaley

Follow Us

 Follow us on Twitter

 

View our profile on LinkedIn

 

This newsletter is intended for the purposes of providing information only and is to be used only for the purposes of guidance.  This newsletter is not intended to be relied upon as the giving of legal advice and does not purport to be exhaustive.

 

Newsletter Contents
The Disposal of Human Remains
Environmentally Friendly Alternatives to Traditional Funeral, Burial and Cremation Services
Tax Tips: Post-Mortem Planning: Pipeline Strategy
Upcoming Programs

Quick Links





 



Contact Info

10 Alcorn Avenue, 

Suite 301
Toronto, ON, M4V 3A9
Tel: (416) 925-7400 
Fax: (416) 925-7464

Kimberly A. Whaley
C.S., TEP.
(416) 355-3250

Mark Handelman
(416) 355-3254

Ameena Sultan
(416) 355-3258

 

Amy Cull
(416) 355-3256

Deborah Stade
(416) 355-3252

Bibi Minoo
(416) 355-3251

Joanne Brigmantas
(416) 355-3255

Marcela Okumura
(416) 355-3253



Join Our Mailing List

If you were forwarded this newsletter and would like to receive future editions please join our mailing list by simply clicking the link above and completing the form.  Thank you. 


Whaley Estate Litigation