Shiner Kideckel Zweig Inc. v. Couture

Shiner Kideckel Zweig Inc. v. Couture

The appeal was dismissed because the motion judge properly exercised her discretion to vary the consent order in the interests of justice given that counsel had been unaware of material facts when consenting, and because there was evidence the Trustee had disclosed the existence and contents of the audit report to a...

Source-derived case information.

Citation
C40933
Parties
Appellant: Shiner Kideckel Zweig Inc., Trustee in Bankruptcy of the Estate of Beetown Honey Products Inc.; Respondent: Donald Couture; Respondent: Beverly Couture
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
22 October 2004
Procedural Posture
Civil / Appeal From Motion Judge's Order Dated October 1, 2003 (variation of Consent Order)
Outcome
Appeal dismissed
Legal Topics
Variation of Consent Order, Litigation Privilege, Disclosure of Audit Report, Trustee Duties
Source Language
en
Bankruptcy Civil Procedure Evidence Privilege Appeal Variation of Consent Order Litigation Privilege Disclosure of Audit Report +1 more

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Parties

Shiner Kideckel Zweig Inc., Trustee in Bankruptcy of the Estate of Beetown Honey Products Inc.

Appellant

Donald Couture

Respondent

Beverly Couture

Respondent

Procedural Posture

Civil / Appeal From Motion Judge's Order Dated October 1, 2003 (variation of Consent Order)

  1. 1 Whether the Court of Appeal should interfere with a motion judge's decision to vary a consent order
  2. 2 Whether litigation privilege protected the audit report held by the Trustee in bankruptcy
  3. 3 Whether disclosure occurred such that privilege did not apply

Ratio Decidendi

The appeal was dismissed because the motion judge properly exercised her discretion to vary the consent order in the interests of justice given that counsel had been unaware of material facts when consenting, and because there was evidence the Trustee had disclosed the existence and contents of the audit report to a third party, justifying disclosure and rendering broader resolution of trustee litigation privilege unnecessary.

Court Disposition

Appeal dismissed

Orders

  • Motion judge's variation of the consent order upheld
  • Costs to the respondent fixed at $11,000 inclusive of disbursements and G.S.T. and all prior motions