Category: Commercial Leases

Categories
Commercial Leases

Tenant Entitled to Damages for Loss of Share Value After Landlord Locked Business Out of Premises

In a recent Ontario Court of Appeal decision, the court found that a tenant was entitled to damages for the loss of share value in her corporation after the landlord locked her and her business out of the premises.

Tenant Lock-Out and Loss of Share Value

In 2006, the tenant’s sister entered into a lease with the then-owner of a building in Toronto. The lease was for premises on the ground floor of the building and contemplated that the premises would be used as a restaurant. It required payment of “Minimum Rent” and “Additional Rent” for the tenant’s share of taxes, utilities and services to the building. 

In 2010, the tenant’s sister assigned the lease to her. An agreement with the then-landlord made amendments to the amount of Minimum Rent and also specified the square footage of the leased premises (1,120 square feet). The other terms and conditions of the lease remained unchanged.

From December 1, 2010 to April 1, 2014, the tenant’s corporation, of which the tenant was the sole shareholder, operated a restaurant on the leased premises. 

The building was purchased by a new landlord in March 2014. 

On April 1, 2014, the new landlord demanded the payment of increased amounts of Minimum Rent and Additional Rent, based on an architect’s evaluation that the leased premises covered a larger area than stated in the original lease. The tenant opposed this increase in rent.

On April 25, 2014, the landlord terminated the tenant’s tenancy for her failure to pay the increased amounts demanded. The locks on the premises were changed, and other than being allowed a brief period to retrieve property from the premises, the tenant was denied the benefit of the premises for the balance of the term of the lease.

As a result, the tenant’s corporation’s restaurant business ceased to operate.

Claiming that the termination of her lease was wrongful, the tenant sued the landlord for the return of her deposit and for damages arising from the breach of the lease. 

Motion Judge Sides with Tenant 

The motion judge found in favour of the tenant, finding that the landlord had wrongfully terminated the lease when it locked the tenant out of the premises.

The motion judge then turned to the issue ofwhether the tenant could claim for the loss of value of her shares. The motion judge found that the termination of the lease caused the restaurant to close, as a result of which the tenant’s shares in the corporation became worthless. He rejected the landlord’s argument that the tenant was not entitled to damages for that loss based on the rule in Foss v. Harbottle. He held that there was an exception to that rule when the company suffers a loss but has no cause of action to recover the loss; in such circumstances the shareholder may sue for the loss of the value of the shares. 

The motion judge awarded the tenant damages of $145,702, made up of the lost share value ($140,614) and a deposit that the landlord was holding ($5,088). 

The landlord appealed.

Foss v. Harbottle Rule

The rule in Foss v. Harbottle prevents shareholders from suing for a loss in the value of their shares brought about by a wrong done to the corporation. The rule, which is well-entrenched in Canadian law, is a consequence of the separate legal personality of the corporation. Just as shareholders (subject to limited exceptions) cannot be sued for acts, debts, defaults or obligations of the corporation, only the corporation has a cause of action for wrongs done to it. 

Issue on Appeal

The primary issue in the appeal was whether the Foss v. Harbottle rule should have been applied to deny the tenant’s claim for the diminution in the value of her shares in the corporation. 

The landlord submitted that the rule in Foss v. Harbottle is part of Ontario law and barred the tenant’s claim for diminution in share value. 

Ontario Court of Appeal Sides with Tenant

The court dismissed the appeal, finding that the wrong had not been done to the corporation, but to the shareholder personally. Only she was a tenant under the lease and only she had a cause of action for its wrongful termination. In such circumstances, the court explained that neither the rule in Foss v. Harbottle nor its rationale applied, stating:

“The rule in Foss v. Harbottle does not preclude an individual shareholder from pursuing a claim for harm done directly to her, assuming the shareholder can make out all the elements of her own cause of action.”

As a result, the court found that the motion judge did not err in allowing the tenant’s claim for diminution in share value.

Get Advice

Baker & Company has adopted all of the COVID-19 safety precautions and vulnerable employees have been invited to work from home. We are fully operational and continuing to work on client assignments. Where possible, meetings are being held via video link or by telephone conference.

At Baker & Company in Toronto, our real estate lawyers take the time to speak with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential. We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of leasing issues. Call us at 416-777-0100 or contact us online for a consultation.

Categories
Commercial Leases

Rights of a Commercial Landlord in the Wake of a Tenant’s Bankruptcy

Though the dust has yet to settle following the economic shutdown due to the COVID-19 pandemic, businesses may be faced with the prospect of bankruptcy. Recently, the Ontario Court of Appeal decided a case concerning the rights of a commercial landlord as a creditor in the bankruptcy of its tenant following the disclaimer of the lease by the trustee in bankruptcy.

What Happened?

The landlord and tenant were parties to a lease dated May 26, 2017 for a space in Toronto. The lease was for a term of ten years and six months, commencing on July 1, 2017 and ending on December 31, 2027.

On March 29, 2018, and without being in default of its obligations under the lease, the tenant made an assignment in bankruptcy. 

The appointed trustee occupied the leased premises and paid occupation rent of $25,698 to the landlord.

On April 20, 2018, the landlord filed a proof of claim in the bankruptcy. The landlord claimed $100,558 as a preferred claim for three months’ accelerated rent, in accordance with the priority of claims prescribed by s. 136(1)(f) of the Bankruptcy and Insolvency Act (the “BIA”). Because the realization of property on the leased premises yielded an amount that was less than the preferred claim ($24,571), the landlord asserted its right to claim the balance of the unrecovered preferred claim ($75,987) as an unsecured creditor.

The landlord also advanced an unsecured claim in the amount of $4,028,111. This represented its claim for rent payable for the balance of the unexpired portion of the term of the lease, together with amounts for tenant inducements consisting of leasehold improvements provided at the landlord’s cost under the lease and free rent for a six-month period. 

In asserting its rights, the landlord relied on the tenant’s obligation under the lease to make certain payments on bankruptcy, including on termination or disclaimer of the lease.

The relevant provision of the lease provided for events of default, including the bankruptcy of the tenant. It also provided for the landlord’s remedies, which included: the payment of three months’ accelerated rent; the right to terminate the lease (with the right to obtain damages for the landlord’s deficiency for the balance of the term); and upon any termination, including disclaimer, payment of the value of the unpaid amount of any tenant inducements calculated over the unexpired term of the lease. 

On April 23, 2018, the trustee issued a notice of disclaimer of the lease. Following the disclaimer, the landlord found a new tenant for the leased premises, effectively mitigating its claim for future rent.

On September 19, 2018, the trustee issued a notice of partial disallowance of claim, allowing only the landlord’s preferred claim in the amount of $24,571 (limited to the actual value of the property on the leased premises), and disallowing the landlord’s unsecured claims.

Lower Court Decision

The landlord appealed the disallowance of its unsecured claim to the Superior Court of Justice. It confined its appeal to its claims under the lease for tenant inducements in the amount of $203,442, including leasehold improvements and free rent, and the balance of the three months’ accelerated rent of $50,289, for a total unsecured claim of $253,731.

The court dismissed the landlord’s appeal. 

At Issue

Two issues were raised in appeal:

1.   Was the landlord entitled to assert a claim for unpaid tenant inducements under the lease as an unsecured creditor in the tenant’s bankruptcy?

2.   Was the landlord entitled to assert the balance of its preferred claim for three months’ accelerated rent as an unsecured creditor in the tenant’s bankruptcy?

Court of Appeal Decision

The Court of Appeal agreed with the lower court’s finding that, in Ontario, the law on the first question was settled many years ago in the 1933 decision Re Mussens Ltd. The court explained the principle as follows: 

“As between the landlord and tenant, the disclaimer of a commercial lease by the tenant’s trustee in bankruptcy brings to an end the future or ongoing obligations of the tenant under the lease. The landlord has no right of compensation or claim as an unsecured creditor for damages in respect of the unexpired term of the lease in relation to the loss of the tenancy as a result of the disclaimer; the landlord is limited to its preferred claim for up to three months’ accelerated rent.”

However, the court did allow the appeal in part to permit the landlord to rank as an unsecured creditor for the unpaid balance of its preferred claim. The court explained that s. 136 of the BIA provides for the priority of certain unsecured claims, including, under s. 136(1)(f), priority for a landlord’s claim for three months’ arrears of rent and three months’ accelerated rent. The court explained that while s. 136 of the BIA sets out a scheme of payment priorities, the landlord’s rights on a tenant’s bankruptcy are established under provincial law. The court stated:

“The Ontario law that defines a commercial landlord’s rights on a tenant’s bankruptcy is found in the Commercial Tenancies Act. The landlord’s preferential lien for rent, and the trustee’s right to retain and to assign the lease, exercisable within three months of the bankruptcy and before the trustee has disclaimed the lease, are set out in s. 38. Section 39 provides for the right of the trustee in bankruptcy, at any time before electing to retain the leased premises, to “surrender or disclaim” the lease.”

As a result, the court concluded that the landlord was not entitled to claim as an unsecured creditor in the bankrupt tenant’s estate for damages relating to the unexpired term of the lease, except to recover the balance of its preferred claim for three months’ accelerated rent, which was specifically provided for by statute.

Get Advice

Baker & Company has adopted all of the COVID-19 safety precautions and vulnerable employees have been invited to work from home. We are fully operational and continuing to work on client assignments. Where possible, meetings are being held via video link or by telephone conference.

At Baker & Company in Toronto, our real estate lawyers take the time to speak with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential. We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of leasing issues. Call us at 416-777-0100 or contact us online for a consultation.

Categories
Commercial Leases

Court Grants Injunction Against Commercial Landlord Who Locked Out Tenant During COVID-19 Pandemic

As a result of the COVID-19 pandemic, a March 19, 2020 Order of Chief Justice Morawetz suspended all residential evictions and/or writs of possession until further notice. However, commercial tenancies were not included in that Order and remain subject to normal rules.

However, in addition, Ontario courts have suspended the hearing of all matters unless they are deemed “urgent”. As a result, any commercial lease disputes must prove to be urgent to be heard by a court, as was the case in a recent Ontario decision, in which the landlord locked his tenant out of the premises in the midst of the COVID-19 pandemic.

What Happened?

The landlord owns a commercial building in Waterloo. The tenant had leased a portion of the building beginning in the 1990s. The parties entered into a written lease dated November 1, 2017. The lease was for a period of five years with an option in favour of the tenant to renew the lease for a further term of five years. 

The lease was for the main floor and a room on the second floor of the leased premises. The tenant operated a licensed restaurant and bar on the main floor and the second floor room was used as an office and storage room.

The lease provided for payment of base rent in the amount of $1,400 per month. The lease also provided for additional rent covering utilities, maintenance costs and other operating costs. Finally, the lease provided that any bona fide offer to purchase the property would be subject to the terms of the lease.

In September, 2019 the landlord advised the tenant that he was interested in selling the property. 

On October 28, 2019, the landlord delivered a handwritten note to the tenant purporting to unilaterally amend several of the terms of the lease including additional rent. The note stated that the tenant was in breach of a zoning bylaw as result of its use of the second floor room as an office. The note ended with an assertion that if the tenant did not immediately pay the additional rent the locks to the premises would be changed.

On January 29, 2020, the landlord wrote again to the tenant claiming numerous breaches of the lease and purporting to terminate the lease effective March 31, 2020. The reasons for terminating the lease included nonpayment of base rent, nonpayment of additional rent, and breach of the Planning Act in relation to the use of the second floor room. On February 14, 2020 counsel for the tenant wrote to the respondent asserting that the applicant had not breached any of the provisions of the lease.

The tenant paid rent on April 1, 2020.

Howewever, on April 7, 2020, the landlord locked the tenant out of the leased premises and posted a Notice of Termination and Forfeiture of Lease on the front door of the building. 

The tenant brought an application pursuant to the Commercial Tenancies Act for various types of relief including that he be allowed immediate access to the leased premises and that the landlord be restrained from entry or re-entry to the leased premises.

A triage judge determined the matter was urgent and it was heard by video conference.

Decision

The court began by explaining that the test for granting an interlocutory injunction is as follows: 

1) The applicant must show that there a serious issue to be tried;

2) The applicant must show that it will suffer irreparable harm if the injunction is not granted; and

3) There must be an assessment regarding which of the parties would suffer the greater harm by the granting or the refusal to grant the injunction.

The court found that the tenant had met each of the three parts of the test for the granting of an interlocutory injunction.

The court found that the landlord’s allegations about the tenant being in breach of the terms of the lease were vague and unsupported by written evidence. In fact, it found that the landlord’s complaints only surfaced after he decided he wanted to sell the property without burdening the new owner with the tenant’s lease. The court found that the tenant had not breached any terms of the lease.

Further, the court found that the tenant would suffer irreparable harm if the injunction was not granted, stating: 

“The action of the [landlord] in locking the [tenant] out of the premises effectively puts an end to the business. The [tenant] will likely suffer a loss of goodwill if it is not allowed to continue in business. […]

[I]f the injunction is refused, the [tenant] will be put out of business. Conversely, if the injunction is granted, the [landlord] will receive exactly what he contracted for when he signed the lease dated November 1, 2017.”

As a result, the court ordered an interlocutory injunction granting the tenant the right to re-enter the property and prohibiting the landlord from re-entering the premises and from interfering with the tenant’s use and enjoyment of the property.

Get Advice

Baker & Company has adopted all of the COVID-19 safety precautions and vulnerable employees have been invited to work from home. We are fully operational and continuing to work on client assignments. Where possible, meetings are being held via video link or by telephone conference.

At Baker & Company in Toronto, our real estate lawyers take the time to speak with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential. We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of leasing issues. Call us at 416-777-0100 or contact us online for a consultation.

Categories
Commercial Leases Real Estate Law

Commercial & Residential Tenancies During COVID-19

The financial instability being faced by both individuals and companies throughout the country due to the ramifications of COVID-19 is creating insecurity in a number of areas, including in residential and commercial leasing matters. Many tenants under financial strain are wondering about their obligation to continue to pay rent during this unprecedented time, while both residential and commercial landlords are unsure of their options if a tenant stops making payments under an existing lease.

Residential Tenancies

In March, the province shut down most businesses in Ontario in order to limit person-to-person contact. In anticipation of the financial challenges this would cause for Ontarians who rent their homes, the government made the following announcement on March 19th:

As the COVID-19 situation continues to evolve, Tribunals Ontario is taking action to safeguard the health and well-being of all Ontarians, while continuing to ensure access to justice. The Landlord and Tenant Board (LTB) has reviewed the appropriate approach to conducting hearings and until further notice the LTB is suspending:

1) All hearings related to eviction applications, unless the matter relates to an urgent issue such as an illegal act or serious impairment of safety; and

2) The issuance of eviction orders, unless the matter relates to an urgent issue such as an illegal act or serious impairment of safety.

While evictions have been halted, there are no mandated regulations in place with respect to a temporary suspension of rent collection or payment obligations for tenants. For those who own homes and pay mortgage payments, most of the major Canadian banks have begun to offer mortgage payment deferrals for this period of time, but there are no similar widespread policies in place for those who pay rent.

The Ontario government has encouraged landlords and tenants to work together in situations where a tenant may have trouble paying rent, to find an arrangement that the parties can both agree to. Given these guidelines, the hope is that parties will come to terms themselves without intervention but the fact remains that many tenants may find themselves facing eviction proceedings once the LTB resumes regular function if they are unable to make up rent arrears at that time.

Commercial Tenancy Considerations

Businesses throughout Ontario have largely been forced to close or dramatically alter their operations in order to facilitate social distancing regulations. For many, this means income has either completely stopped or been severely curbed for an undefinable period of time. Even within the first couple of weeks after the closures, many businesses were forced to lay off staff and make other arrangements to reduce immediate expenses. For those businesses that lease their property, the current situation has placed a particular strain on those obligations, which generally make up one of a business’s most significant monthly expenses. While the government has encouraged commercial landlords to make arrangements with their tenants during this time, they are not required to do so.

Typically, a commercial landlord has a few options with respect to enforcement a lease if the tenant stops paying rent. The landlord can sue for payment of the rent owed, seize property from the tenant, or re-enter the property to force the tenant out if the lease allows for such a right or the landlord receives a court order to this effect. If a landlord wishes to terminate the lease in order to find a new tenant, they may do so pursuant to s. 18 of the Commercial Tenancies Act, however, landlords are generally advised to obtain a court order before taking this step. With a court order, a landlord can then have the Sheriff’s Department execute a writ of possession and remove the existing tenant from the premises.

However, along with other services, the Ontario government has chosen to close courts in the province to all but emergency matters for the time being, significantly restricting the matters a court will hear to urgent family and criminal matters. As a result, it will be difficult for a commercial landlord to obtain a court order granting the termination of a lease during this time.

For now, commercial landlords should try to work with clients to make mutually agreeable arrangments for the duration of the emergency order while planning for future enforcement of a lease’s terms, if necessary, once business in the province begins to return to normal.

At Baker & Company in Toronto, our real estate lawyers take the time to meet with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential. We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of leasing issues. Call us at 416-777-0100 or contact us online for a consultation.

Categories
Commercial Leases Litigation Real Estate Law

Anticipatory Breach of Contract & Limitation Periods

We have previously provided a general overview with respect to limitation periods in litigation. It is well established that the general limitation period extends for two years once a claim has been discovered, but when does the limitation period begin to run on a claim for anticipatory breach of contract? When does the clock start to run if there is no breach, but the Plaintiff has been made aware that a breach is imminent? This question was addressed by an Ontario court in a recent decision.

Changes to Commercial Property Impacted Plaintiff’s Business

The Plaintiff owned a commercial car wash operation in London, Ontario, and leased the property where the car wash was located from the Defendant. In addition to the car wash, the property contained other businesses including a gas station, a convenience store and a coin-operated car wash facility (this was separate from the Plaintiff’s business, which provided an automatic wash as well as interior car detailing services). The Defendant began to redevelop the land surrounding the car wash and demolished the gas bar, coin-op car wash and the convenience store. The Defendant also obtained site plan approval from the city to construct commercial buildings on the property to house various retail businesses.

The construction of one building on the property, as well as the addition of garbage dumpsters in front of the car wash, had reduced the visibility of the car wash from the main road.

The lease between the Plaintiff and the Defendant contained the following clause:

… the Lessor shall have the right to alter or modify the parking lot or the means of ingress or egress thereto provided that such alteration or modification shall not impede or limit any access to or from the leased premises nor will it divide or separate in any way the leased premises from any part of the Lessor’s lands, and further provided that any such alteration or modification shall not affect the marketability or potential marketability of the Lessee’s product from the leased premises in any adverse way; [Emphasis added]

The Plaintiff alleged that there had been a drop in the number of cars at the car wash, and largely attributed the change to the modifications made by the Defendant. In particular, the Plaintiff said that the reduced visibility of the car wash from the road had negatively impacted the number of cars the business had been servicing in the years following the changes.

Plaintiff Discovered the Potential Breach More Than 2 Years Before Bringing Action

The Plaintiff was made aware of the Defendant’s plan to construct a new building on the property in 2013. In response, the Plaintiff wrote a letter to the Defendant saying that this would block visibility of the car wash from the road and requested that the plans for the building be abandoned. The Defendant responded in early 2014, saying that they would be going ahead with their plans for construction. In addition to the planned buildings, the Defendant installed two garbage dumpsters in front of the entrance to the car wash in 2014 and constructed a concrete pad adjacent to the car wash in the same year. This also had the effect of reducing the visibility of the car wash from the main road.

The Plaintiff sought damages for the reduction in car count at their business owing to the loss of visibility and the Defendant defended on the grounds that the action was statute-barred. The discovery of the planned construction occurred in 2013, and the other incidents had taken place throughout 2014. The Plaintiff brought the action in February of 2016. The Defendant claimed this was outside of the 2-year limitation period.

The Defendant specifically claimed that the letter from the Defendant’s lawyer, dated January of 2014, constituted an anticipatory breach of the commercial lease and therefore the clock started to run on that date. However, the court held that:

[A] claim is not necessarily discovered when a party commits an anticipatory breach of contract as the innocent party may choose to treat the contract at an end and sue for damages, or it may treat the contract as subsisting and continue to press for performance of the contract and bring an action once the promised performance fails to materialize

In the case at hand, the Plaintiff chose to treat the contract as not yet breached and continued to perform its duties under the contract while pressing the Defendant to abandon the plans that would negatively impact the Plaintiff’s business. Given that, the complaint didn’t arise until the Plaintiff had experienced the reduction in car count, somewhere within the two-year limitation period.

This case should be of some comfort to parties concerned that advance knowledge of a potential breach may preclude them from seeking damages in court. However, it is always best to speak with an experienced lawyer as soon as possible to properly ascertain your position with respect to litigation and ensure that you are fully aware of any time limitations you may face when it comes to commencing an action. While limitation periods may seem cut and dry, as evidenced by this case, they can actually be quite complex depending on the specific circumstances involved.

At Baker & Company, our Toronto commercial real estate and litigation lawyers take the time to meet with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential.  We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of transactions, or through litigation. Call us at 416-777-0100 or contact us online for a consultation.

Categories
Commercial Leases Real Estate Law

Tenants in Default & Relief for Forfeiture

Can a party in default of a commercial lease successfully claim relief for forfeiture? This was the question recently considered by the Ontario Court of Appeal (ONCA) when a tenant who had been found in default of its commercial lease sought to exercise its right to renew and was refused by the landlord.

Dispute Over Terms

The plaintiff in the case was a commercial tenant renting space in a cold storage facility owned by the defendant landlord. The lease was for a term of five years and contained a clause allowing the landlord to pass on certain increases in energy costs to the tenant. The lease granted the tenant the right to renewal, providing the tenant was not in default of any terms of the lease at the time of renewal.

Approximately three years after the start of the lease, an issue arose around the term with respect to the increased energy costs. The landlord took the position that it was entitled to additional payment under the clause, while the tenant refused. The tenant continued to make its rent payments each month but refused to pay the additional fees charged for the increased energy costs. A few months into this dispute, the landlord informed the tenant that it considered the tenant’s failure to pay these costs a default under the terms of the lease. The landlord reiterated its position two more times and notified the tenant that it would not be permitted to renew the lease if it failed to pay the energy costs.

The Initial Application

A few months later, the tenant informed the landlord that it wished to exercise its option to renew. The landlord rejected this, owing to the tenant’s default. Five years after the start of the original lease, the tenant brought an application seeking an interpretation of the increased energy clause of the lease. The tenant sought the following relief:

  1. a declaration that it was not in default under the terms of the lease and that it had properly exercised the option to renew; and
  2. if the tenant was found in default, then a declaration that it was entitled to relief from forfeiture.

The application judge held that the tenant was, in fact, in default under the terms of the lease and as such, was not entitled to exercise its option to renew. With respect to relief for forfeiture, the judge looked to the reasoning in 120 Adelaide Leaseholds Inc. v. Oxford Properties Canada Ltd., and determined that the court’s equitable jurisdiction to grant relief for forfeiture was limited in cases where there is a failure to perform a condition precedent to a right, as in the case at hand. The court held that the tenant had failed to complete its due diligence with respect to securing the right to renew, and therefore was not entitled to relief for forfeiture.

The Appeal

The tenant appealed the application’s judge finding with respect to forfeiture. The tenant argued that the judge had applied the wrong test when determining the court’s discretion to grant relief for forfeiture and that the test from Saskatchewan River Bungalows Ltd v. Maritime Life Assurance Company should have been used instead.

The ONCA dismissed the appeal, finding that the applications judge had used the appropriate test. There was no question the tenant was in default of the lease. The court stated:

[W]here preconditions to the renewal of a lease are in issue, the jurisdiction to grant relief from forfeiture is narrower than the three-pronged test applied in cases such as Saskatchewan River Bungalows. With respect to the renewal of a lease, a precondition for the exercise of any such equitable discretion is that the tenant has made diligent efforts to comply with the terms of the lease which are unavailing through no default of his or her own[.]

The tenant in this case would have been better off paying the increased energy costs and maintaining its good standing under the lease. It could have then sought a return of those funds had the court found that the clause did not require they pay additional funds to the landlord. By refusing to pay, the tenant found itself in default with no options for relief, and without a place to operate its business.

At Baker & Company in Toronto, our real estate lawyers take the time to meet with you and understand your unique needs in order to guide you through your real estate matter, whether commercial or residential.  We rely on our broad base of experience and expertise to provide exceptional legal advice and risk management in a variety of transactions, or through litigation. Call us at 416-777-0100or contact us online for a consultation.