B&M HANDELMAN INVESTMENTS LIMITED, E. MANSON …...court file no. cv-18-593698-00cl ontario superior court of justice [commercial list] b e t w e e n: b&m handelman investments limited,

Court File No. CV-18-593698-00CL

ONTARIO

SUPERIOR COURT OF JUSTICE

[COMMERCIAL LIST]

B E T W E E N:

B&M HANDELMAN INVESTMENTS LIMITED, E. MANSON INVESTMENTS

LIMITED, BAMBURGH HOLDINGS LIMITED, 4055845 CANADA INC., JEFFREY

GERTNER, 5K INVESTMENTS INC., 558678 ONTARIO LIMITED, and PAUL

HERBERT PROFESSIONAL CORPORATION INC.. Applicants

- and -

SKYMARK PROPERTIES 1 CORPORATION

also known as SKYMARK PROPERTIES I CORPORATION

Respondent

IN THE MATTER OF SECTION 243(1) OF THE BANKRUPTCY AND INSOLVENCY

ACT, R.S.C. 1985 C. B-3, AS AMENDED, AND SECTION 101 OF THE COURTS OF

JUSTICE ACT, R.S.O. 1990 C. C.43, AS AMENDED

MOTION RECORD (Receiver's Motion for Directions Returnable May 2, 2019)

April 26, 2019

TO: SERVICE LIST

BLANEY MCMURTRY LLP

Barristers & Solicitors

2 Queen Street East, Suite 1500

Toronto ON M5C 3G5

Eric Golden LSUC #38239M (416) 593-3927 (Tel)

(416) 593-5437 (Fax)

Email: [email protected]

Chad Kopach LSUC #48084G (416) 593-2985 (Tel)

(416) 593-5437 (Fax)


Lawyers for the Receiver

Rosen Goldberg Inc.

SERVICE LIST

(as at April 26, 2019)

TO:

CHAITONS LLP 5800 Yonge Street, 10th Floor

Toronto, ON M2N 7E9

GEORGE BENCHETRIT

(416) 218-1141 (Tel)

(416) 218-1841 (Fax)


MICHAEL KRIL-MASCARIN

(416) 218-1123 (Tel)

(416) 218-1848 (Fax)


Lawyers for the Applicants

AND TO: ROSEN GOLDBERG

5255 Yonge Street, Suite 804

Toronto, ON M2N 6P4

BRAHM ROSEN

(416) 224-4210 (Tel)

(416) 224 4330 (Fax)


Receiver

AND TO: BRAUTI THORNING LLP

161 Bay Street, Suite 2900

Toronto, ON M5J 2S1

CAITLIN FELL (416) 304-7002 (Tel)

(416) 362-8410 (Fax)


STEVEN WEISZ (416) 304-6522 (Tel)

(416) 362-8410 (Fax)


Lawyers for Skymark I Properties Corporation,

also known as Skymark 1 Properties Corporation

AND TO: MILLER THOMSON LLP

40 King Street West

Suite 5800

Toronto, ON M5H 3S1

JAMES ZIBARRAS (416) 595-2998 (Tel)

(416) 595-8695 (Fax)


Lawyers for Skymark I Properties Corporation,

also known as Skymark 1 Properties Corporation

AND TO: RUBENSTEIN SIEGEL

1210 Sheppard Ave. E.

Suite 701

North York, ON M2K 1E3

JOSHUA J. SIEGEL (416) 499-5252 ext. 227 (Tel)

(416) 499-2290 (Fax)


Lawyers for 1764180 Ontario Ltd.

AND TO: A. PEARLMAN PARALEGAL SERVICES

PROFESSIONAL CORPORATION

75 First Street, Box 213

Orangeville, ON L9W 5B6

ALLEN PERLMAN (519) 943-0590 (Tel)

(519) 943-0591 (Fax)


Representative of

Laser Heating & Air Conditioning Inc.

AND TO: DJD LAW PROFESSIONAL CORPORATION

1186 Eglinton Avenue West

Toronto, ON M6C 2E3

ELI KARP (416) 769-4107 (Tel)

(416) 352-7638 (Fax)


Lawyers for 2455657 Ontario Inc.

AND TO: ONTARIO MINISTRY OF FINANCE

Office of Legal Services

33 King Street West, 6th Floor

Oshawa, Ontario L1H 8H5

KEVIN J. O’HARA

(905) 433-6934 (Tel)

(905) 436-4510 (Fax)


Lawyers for the Ministry of Finance (Ontario)

AND TO: CANADA REVENUE AGENCY

c/o Department of Justice Ontario Regional Office

The Exchange Tower, Box 36

130 King Street, Suite 3400

Toronto, Ontario M5X 1K6

DIANE WINTERS

(416) 973-3172 (Tel)

(416) 973-0810 (Fax)


Lawyers for Canada Revenue Agency

mailto:[email protected]



ONTARIO


[COMMERCIAL LIST]

B E T W E E N:





- and -



Respondent




I N D E X

Tab Page

1. Notice of Motion returnable May 2, 2019 ................................................................. 1-8

2. Second Report of the Receiver dated April 26, 2019 ................................................ 9-22

A. Appendix “A” – Appointment Order of Justice McEwen dated March 19, 2018 ..... 23-40

B. Appendix “B” – Approval Order and Sales Approval and Vesting Order of Justice

Dunphy dated June 27, 2018 ......................................................................................

41-56

C. Appendix “C” – First Report of the Receiver dated June 15, 2018 (without

appendices) ................................................................................................................

57-72

D. Appendix “D” – Receiver’s Statement of Receipts and Disbursements ................... 73-74

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E. Appendix “E” – Opinion Letter dated April 12, 2019 ............................................... 75-89

F. Appendix “F” – Series of emails between Eric Golden and Eli Karp from March 25,

2019 to April 18, 2019 ...............................................................................................

90-95

G. Appendix “G” – Affidavit of Glenn Estrabillo sworn August 28, 2018 (the

“Estrabillo Affidavit”), with Exhibits 12 to 16 ........................................................

96-126

H. Appendix “H” – Exhibits F, L and P to the Estrabillo Affidavit ............................... 127-154

I. Appendix “I” – Series of emails between Eric Golden and Josh Siegel from

November 16, 2018 to April 8, 2019 .........................................................................

155-188

J. Appendix “J” – Claim for Lien and Certificate of Action of Laser Heating & Air

Conditioning Inc. (“Laser”), and Order of Master Wiebe ........................................

189-198

K. Appendix “K” – Small Claims Court Plaintiff’s Claim of Laser, and Defence of

Skymark Properties I Corporation .............................................................................

199-208

L. Appendix “L” – Fee Affidavit of Brahm Rosen sworn April 9, 2019 ....................... 209-227

M. Appendix “M” – Fee Affidavit of Chad Kopach sworn April 24, 2019 .................... 228-265

N. Appendix “N” – Fee Affidavit of Lawrence Zimmerman affirmed April 15, 2019 .. 266-273


ONTARIO


[COMMERCIAL LIST]

B E T W E E N:





- and -



Respondent




NOTICE OF MOTION

(Receiver's Motion for Directions Returnable May 2, 2019)

Rosen Goldberg Inc., in its capacity as receiver and manager (in such capacity, the

“Receiver”) without security, over lands and premises registered in the name of the Respondent,

Skymark Properties 1 Corporation also known as Skymark Properties I Corporation (“Skymark”

or the “Debtor”), municipally known as 1 William Morgan Drive, Toronto, Ontario (the “WM

Drive Property”), and the remaining assets and undertaking of the Debtor acquired for or used

in relation to the WM Drive Property, will make a motion to a Judge presiding over the

Commercial List, on May 2, 2019, at 10:00 a.m., or as soon thereafter as the motion can be

heard, at 330 University Avenue, Toronto, Ontario.

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PROPOSED METHOD OF HEARING: The motion is to be heard orally.

THE MOTION IS FOR AN ORDER:

1. if necessary, abridging the time for service of the Receiver’s Motion Record, validating

service of the Motion Record, and dispensing with further service thereof;

2. for directions regarding the surplus funds available for distribution held by the Receiver

from the sale of the WM Drive Property following payout of the Applicants’ first

mortgage, currently estimated in the amount of approximately $236,113, less the fees

and costs of the Receiver from April 3, 2019, and its counsel from on or about April 19,

2019 (the “Surplus Funds”), and regarding a deposit paid by Skymark in the amount of

$100,000.00 in respect of an aborted purchase of a property in Lindsay, Ontario (the

“Lindsay Property”), currently held by the solicitor for the vendor;

3. approving of the activities and proposed activities described in the Receiver’s Second

Report dated April 26, 2019 (the “Second Report”);

4. approving and accepting the Receiver’s Interim Statement of Receipts and Disbursements

for the period from March 19, 2018 to April 25, 2019, as set out in Appendix “D” to the

Second Report;

5. approving the fees and disbursements of the Receiver for the period from March 6, 2018,

to April 2, 2019, the fees and disbursements of Blaney McMurtry LLP (“Blaneys”) for

the period from May 14, 2018, to April 18, 2019, and the fees and disbursements of

Zimmerman & Associates (“Zimmerman”) from March 19 to July 10, 2018, relating to

the closing of the sale of the WM Drive Property;

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6. in the event that (i) the Canada Revenue Agency (“CRA”) does not issue a clearance

certificate in respect of Skymark prior to the return of the within motion, and/or (ii) the

Court does not make an Order distributing the Surplus Funds, an Order authorizing the

Receiver to file an assignment in bankruptcy on behalf of Skymark;

7. if necessary, amending the Appointment Order to provide authority for the Receiver to

assign Skymark into bankruptcy; and

8. such further and other relief as counsel may advise and this Honourable Court deems just.

THE GROUNDS FOR THIS MOTION ARE:

Background

1. by Order of Justice McEwen dated March 19, 2018 (the “Appointment Order”), Rosen

Goldberg Inc. was appointed receiver and manager over the WM Drive Property, and the

remaining assets and undertaking of the Debtor acquired for or used in relation to the

WM Drive Property;

2. on June 27, 2018, Justice Dunphy made a Sale Approval and Vesting Order for the WM

Drive Property. On the same day, Justice Dunphy made an Approval Order that, among

other things, provided that upon completion of the sale of the WM Drive Property, funds

from the net proceeds of sale be distributed to the Applicants in full satisfaction of their

first mortgage over the WM Drive Property;

3. following the sale of the WM Drive Property on July 9, 2018, the Receiver paid the

Applicants $2,992,439.00, representing the amount owing under their first mortgage;

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4. the Receiver is currently holding net proceeds of sale of the WM Drive Property totaling

$236,113;

5. the second mortgagee, 2455657 Ontario Corporation (“245 Ontario”), held the second

mortgage over the WM Drive Property in the face amount of $600,000 (the “Second

Mortgage”);

Basis for Motion for Directions

Amount Due Under the 245 Mortgage

6. pursuant to the Receiver’s request for a payout statement and proof of advances regarding

the Second Mortgage, 245 Ontario delivered a payout statement dated April 5, 2019 (the

“Payout Statement”), stating that the indebtedness owing under the Second Mortgage

was $915,770.10, plus a per diem. The Payout Statement states, among other things, that

the Second Mortgage “resulted as part of a loan made to [Arash Missaghi] using [the

WM Drive Property] as collateral to satisfy arrears on another property”. As for proof of

advances, the Receiver was referred to certain paragraphs of the affidavit of Glenn

Estrabillo sworn August 28, 2018 (the “Estrabillo Affidavit”) in another receivership

proceeding;

7. the paragraph of the Estrabillo Affidavit that purports to constitute back up of advances

references five payments in respect of “1 William Morgan” totaling $275,000.00. The

attachments to the Estrabillo Affidavit in respect of these five advances do not include

cheques payable to Skymark. It is not clear how the advances in the Estrabillo Affidavit

support the $915,770.10 purportedly outstanding under the Second Mortgage pursuant to

the Payout Statement;

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8. the Blaneys security opinion in respect of the Second Mortgage, beyond the usual

qualifications, is dependent on 245 Ontario providing the consideration for the Second

Mortgage, and proving the advances under that mortgage;

The Lindsay Property Deposit

9. the Receiver has become aware that in or about July, 2016, Skymark paid a deposit in the

amount of $100,000.00 in respect of an aborted purchase of the Lindsay Property (the

“Lindsay Property Deposit”). The Lindsay Property Deposit is being held by the

solicitor for the vendor, 1764180 Ontario Ltd. (the “Lindsay Vendor”). Although the

Lindsay Property subsequently sold to another purchaser for an amount greater than that

agreed to by Skymark, the Lindsay Vendor has made a claim for forfeiture of the full

Lindsay Property Deposit pursuant to the terms of the underlying agreement of purchase

and sale. Further, the Lindsay Vendor alleges damages resulting from Skymark’s failure

to close on the Lindsay Property;

10. 245 Ontario has made a claim to the Lindsay Property Deposit, either as a secured

creditor (245 Ontario has, to date, not produced a security agreement in this regard), or as

an unsecured creditor for the shortfall on its Second Mortgage;

11. given the limited nature of the Appointment Order, the Receiver does not appear to have

authority to deal with the Lindsay Property Deposit issue on behalf of Skymark;

Construction Lien Claim

12. as part of the sale of the WM Drive Property, a claim for lien in the amount of $11,756.00

registered by Heating & Air Conditioning Inc. (“Laser”), and the related certificate of

action, were vested off pursuant to the Sale Approval and Vesting Order. As a result of

various and numerous inquiries by the Receiver’s counsel, the Receiver was recently

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provided with a copy of an Order of Master Wiebe dated July 2, 2015 (the “Wiebe

Order”) pursuant to which, among other things, Laser’s Claim for Lien and related

Certificate of Action were ordered discharged, and the lien action was dismissed;

13. further, Laser had commenced a Small Claims Court action against Skymark seeking

payment of $10,057.28 on account of maintenance and other work done at the WM

Drive Property. This action has been stayed since the Appointment Order;

Bankruptcy Filing

14. apart from the amount potentially due to 245 Ontario pursuant to its Second Mortgage, a

possible CRA claim in respect of HST, the claim of the Lindsay Property Vendor, and

the claim of Laser, the Receiver has no information about any other Skymark creditors of

note. However, the Receiver has not initiated a claims process given the limitations on

the scope of the Receivership over Skymark;

15. in the event CRA does not issue a clearance certificate and the Court determines that

there are amounts owing under the Second Mortgage, the Receiver is requesting the

authority to file an assignment in bankruptcy on behalf of Skymark, with the costs of the

bankruptcy filing funded from the Surplus Funds;

16. similarly, if the Court is not prepared to make an Order distributing the Surplus Funds to

245 Ontario, the Receiver is also requesting the authority to file an assignment in

bankruptcy on behalf of Skymark to expand the receivership to all of Skymark’s assets

and undertaking, and administer some form of claims process in the receivership;

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Receipts and Disbursements and Professional Fees

17. the Interim Statement of Receipts and Disbursements of the Receiver attached as

Appendix “D” to the Second Report is a fair and accurate representation of the funds

received and disbursed directly by the Receiver since the Appointment Order herein;

18. the Receiver retained Blaneys as its independent counsel in respect of the Receivership.

Zimmerman was retained to process the sale of the WM Drive Property for the Receiver;

19. the fees and disbursements of the Receiver, Blaneys and Zimmerman that are sought to

be approved on this motion are fair and reasonable in the circumstances;

20. section 249 of the Bankruptcy and Insolvency Act, R.S.C. 1985, c. B.3;

21. Rules 2.03, 3.02, 37 and 41.05 of the Rules of Civil Procedure, R.R.O. 1990, Reg. 194;

and

22. such further and other grounds as counsel may advise and this Honourable Court may

permit.

THE FOLLOWING DOCUMENTARY EVIDENCE WILL BE USED ON THE

HEARING OF THE MOTION:

1. the First Report of the Receiver;

2. the Second Report of the Receiver;

3. the Affidavit of Brahm Rosen sworn April 9, 2019;

4. the Affidavit of Chad Kopach sworn April 24, 2019;

5. the Affidavit of Lawrence Zimmerman affirmed April 15, 2019; and,

6. such further and other grounds as counsel may advise and this Honourable Court may

permit.

7

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April 26, 2019 BLANEY MCMURTRY LLP



Toronto ON M5C 3G5


(416) 593-5437 (Fax)



(416) 593-5437 (Fax)


Lawyers for the Receiver

Rosen Goldberg Inc.

TO:

SERVICE LIST

8


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Appendix “A”

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Appendix “B”

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Appendix “C”

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Appendix “D”

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Appendix “E”

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Appendix “F”

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Appendix “G”

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Appendix “H”

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Appendix “I”

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Appendix “J”

189

LRO # 80 Construction Lien Registered as A T3557481 on 2014 04 14 at 10:06

The applicant(s) hereby applies to the Land Registrar. yyyy mm dd Page 1 of 1

Properties

PIN 10369 − 0019 LT Redescription

Description NO CHANGE

Address 1 WILLIAM MORGAN DRIVE

TORONTO

Consideration

Consideration $11,756.22

Claimant(s)

Name LASER HEATING & AIR CONDITIONING INC.

Address for Service c/o 204−1220 Sheppard Avenue East,

Toronto, Ontario M2K 2S5

I, ROBERT LORION, am the agent of the lien claimant and have informed myself of the facts stated in the claim for lien and believe them

to be true.

I, ROBERT LORION, have the authority to bind the corporation.

This document is not authorized under Power of Attorney by this party.

Statements

Name and Address of Owner Cinderella Productions Inc., 1 William Morgan Drive, Toronto, Ontario M4H 1N6 Name and address of

person to whom lien claimant supplied services or materials Cinderella Productions Inc., 1 William Morgan Drive, Toronto, Ontario M4H

1N6 Time within which services or materials were supplied from 2013/03/21 to 2014/03/21 Short description of services or materials that

have been supplied HVAC and repairs to original system Contract price or subcontract price $11,756.22 (incl. of HST) Amount claimed as

owing in respect of services or materials that have been supplied $11,756.22 (incl. of HST)

The lien claimant claims a lien against the interest of every person identified as an owner of the premises described in said PIN to this lien

Signed By

Jack Copelovici 204−1220 Sheppard Ave. E.

Toronto

M2K 2S5

acting for

Applicant(s)

Signed 2014 04 14

Tel 4164940910

Fax 4164945480

I have the authority to sign and register the document on behalf of the Applicant(s).

Submitted By

JACK COPELOVICI LAW OFFICE 204−1220 Sheppard Ave. E.

Toronto

M2K 2S5

2014 04 14

Tel 4164940910

Fax 4164945480

Fees/Taxes/Payment

Statutory Registration Fee $60.00

Total Paid $60.00

File Number

Claimant Client File Number : 32−053 − LASER RECEIVABLES − WILLIAM MOR

190

LRO # 80 Certificate Registered as A T3600898 on 2014 06 06 at 09:30

The applicant(s) hereby applies to the Land Registrar. yyyy mm dd Page 1 of 4

Properties

PIN 10369 − 0019 LT

Description PCL B−2 SEC M736; PT BLK B PL M736 LEASIDE; PT BLK C PL M736 LEASIDE PT 1, 3,

R1083; TORONTO , CITY OF TORONTO

Address TORONTO

Party From(s)

Name LASER HEATING & AIR CONDITIONING INC.

Address for Service c/o 204−1220 Sheppard Avenue East,

Toronto, Ontario M2K 2S5

I, Robert Lorion, have the authority to bind the corporation.

This document is not authorized under Power of Attorney by this party.

Statements

This document relates to registration no.(s)AT3557481

Schedule: See Schedules

Signed By

Jack Copelovici 204−1220 Sheppard Ave. E.

Toronto

M2K 2S5

acting for Party

From(s)

Signed 2014 06 06

Tel 416−494−0910

Fax 416−494−5480

I have the authority to sign and register the document on behalf of the Party From(s).

Submitted By

JACK COPELOVICI LAW OFFICE 204−1220 Sheppard Ave. E.

Toronto

M2K 2S5

2014 06 06

Tel 416−494−0910

Fax 416−494−5480

Fees/Taxes/Payment

Statutory Registration Fee $60.00

Total Paid $60.00

File Number

Party From Client File Number : 32−053 CINDERELLA CERT OF ACT

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Court File No. CV-14-505369

ONTARIOSUPERIOR COURT OF JUSTICE

IN THE MATTER OF the Construction Lien Act, R.S.O. 1990, c. C.30

MASTER ) THURSDAY, THE 2^^)) DAY OF JULY, 2015

EEN:

LASER HEATING & AIR CONDITIONING INC.Plaintiff

- and -

CINDERELLA PRODUCTIONS INC., THE EQUITABLE TRUST COMPANY,B & M HANDELMAN INVESTMENTS LTD., E. MANSON INVESTMENTSLIMITED, BANBURGH HOLDINGS LTD., 4055845 CANADA INC., PAUL

HERBERT PROFESSIONAL CORPORATION, 558678 ONTARIO LTD., JEFFREYGERTNER and ROBERT HANDELMAN

Defendants

ORDER

THIS MOTION, made by the Defendants B & M Handelman Investments Ltd., E.

Manson Investments Limited, Banburgh Holdings Ltd., 4055845 Canada Inc., Paul

Herbert Professional Corporation, 558678 Ontario Ltd., Jeffrey Gertner and Robert

Handelman, for an Order was heard this day at the Superior Court of Justice, 393

University Ave, Toronto, Ontario, M5G 1E6.

195

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ON READING the Consent of the Plaintiff Moving Party, filed, and the Affidavit of

Lawrence Zimmerman affirmed June 5, 2015 and exhibits thereto annexed, and

hearing from counsel for the Defendants B & M Handelman Investments Ltd., E.

Manson Investments Limited, Banburgh Holdings Ltd., 4055845 Canada Inc., Paul

Herbert Professional Corporation, 558678 Ontario Ltd., Jeffrey Gertner and Robert

Handelman,

1. THIS COURT ORDERS that the time for service and filing of the Notice of

Motion and the Motion Record is hereby abridged so that this Motion is

properly returnable today and hereby dispenses with further service thereof.

2. THIS COURT ORDERS that any court materials in these proceedings may

be served by emailing a PDF or other electronic copy of such materials to

counsels' email addresses.

3. THIS COURT ORDERS this action is hereby dismissed without costs.

4. THIS COURT ORDERS that the Claim for Lien registered on April 14,

2014 as Instrument No. AT3557481 in the Land Registry Office for the

Registry Division of Toronto as against the lands and premises municipally

known as 1 William Morgan Drive, Toronto, Ontario and more particularly

described as PIN 10369-0019 LT - PCL B-2 SEC M736; PT BLK B PL M736

LEASIDE; PT BLK C PL M736 LEASIDE PT 1, 3, R1083; TORONTO ,

CITY OF TORONTO be and the same is hereby discharged.

5. THIS COURT ORDERS that the Certificate of Action registered on June 6,

2014 as Instrument No. AT3600898 in the Land Registry Office for the

Registry Division of Toronto as against the lands and premises municipally

known as 1 William Morgan Drive, Toronto, Ontario and more particularly

described as PIN 10369-0019 LT - PCL B-2 SEC M736; PT BLK B PL M736

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LEASIDE; PT BLK C PL M736 LEASIDE PT 1, 3, R1083; TORONTO ,

CITY OF TORONTO be and the same is hereby vacated.

6. THIS COURT ORDERS that the Moving Party serve this Order on the

Plaintiff forthwith after entry.

ENTERED AT ) INSCRIT ATORONTOON / BOOK NO:LE / DANS LB REGISTRE NO.;

JUL - 2 2015

197

. LASER HEATING & AIR CONDITIONING INC.Plaintiff

B & M HANDELMAN INVESTMENTS LTD. et alDefendants

Court FUe No. CV-14-505369

ONTARIOSUPERIOR COURT OF JUSTICE

Proceeding commenced at Toronto

ORDER

Lawrence F. WallachBarrister and Solicitor302-4580 Dufferin StToronto ON M3H 5Y2

LSUC: 24289A

Tel: (416)661-5600Fax: (416)663-4424

Lawyer for the DefendantsB & M Handelman Investments Ltd.,E. Manson Investments Limited,Banburgh Holdings Ltd., 4055845Canada Inc., Paul Herbert ProfessionalCorporation, 558678 Ontario Ltd.,Jeffrey Gertner and Robert Handelman

198

Appendix “K”

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Appendix “L”

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Appendix “M”

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Appendix “N”

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IN THE MATTER OF SECTION 243(1) OF THE BANKRUPTCY AND INSOLVENCY ACT, R.S.C. 1985 C. B-3, AS AMENDED, AND SECTION 101 OF

THE COURTS OF JUSTICE ACT, R.S.O. 1990 C. C.43, AS AMENDED


B&M HANDELMAN INVESTMENTS LIMITED, ET AL.

Applicants

and SKYMARK PROPERTIES 1 CORPORATION, ET AL.

Respondent

ONTARIO


[COMMERCIAL LIST]

Proceeding commenced at Toronto

MOTION RECORD

(Receiver's Motion for Directions Returnable May 2, 2019)

BLANEY MCMURTRY LLP



Toronto ON M5C 3G5


(416) 593-5437 (Fax)



(416) 593-5437 (Fax)


Lawyers for the Receiver, Rosen Goldberg Inc.



Documents

B&M HANDELMAN INVESTMENTS LIMITED, E. MANSON …...court file no. cv-18-593698-00cl ontario superior court of justice [commercial list] b e t w e e n: b&m handelman investments limited,