Bromley v. Furlong

Bromley v. Furlong

The Court held that appeals under the Divorce Act are governed by a thirty day limitation; the applicant's extension application with an attached notice of appeal was sufficient so that the notice was deemed filed within the thirty day period for Divorce Act matters, making a formal extension unnecessary, while the...

Source-derived case information.

Citation
2012 NLCA 3
Parties
Appellant: Victoria Bromley (Furlong); Respondent: Robert Furlong
Court
Newfoundland and Labrador Court of Appeal
Jurisdiction
Canada
Judgment Date
17 January 2012
Procedural Posture
Family Law Appeal (divorce Act and Change of Name Act) / Application for Extension of Time to File Notice of Appeal; Appeal Pending
Outcome
Application for extension of time unnecessary as notice of appeal deemed filed within thirty days for Divorce Act matters; directions issued for appeal record and schedule; thirty day Rules limitation applies to Change of Name Act order; costs in the cause.
Legal Topics
Extension of Time, Limitation Periods for Appeals, Appeal Book Requirements, Costs
Source Language
en
Family Law Divorce Civil Procedure Appeals Extension of Time Limitation Periods for Appeals Appeal Book Requirements Costs

Source-derived case record

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Parties

Victoria Bromley (Furlong)

Appellant

Robert Furlong

Respondent

Procedural Posture

Family Law Appeal (divorce Act and Change of Name Act) / Application for Extension of Time to File Notice of Appeal; Appeal Pending

  1. 1 Whether the ten day interlocutory appeal limitation in rule 57.02 applied
  2. 2 Whether a notice of appeal attached to an extension application is deemed filed within the 30 day limitation under the Divorce Act
  3. 3 Whether the Change of Name Act order is governed by the Rules' thirty day limitation

Ratio Decidendi

The Court held that appeals under the Divorce Act are governed by a thirty day limitation; the applicant's extension application with an attached notice of appeal was sufficient so that the notice was deemed filed within the thirty day period for Divorce Act matters, making a formal extension unnecessary, while the separate Change of Name Act final order is governed by the Rules' thirty day limitation; accordingly the extension application need not be granted and procedural directions for the appeal were given.

Court Disposition

Application for extension of time unnecessary as notice of appeal deemed filed within thirty days for Divorce Act matters; directions issued for appeal record and schedule; thirty day Rules limitation applies to Change of Name Act order; costs in the cause.

Orders

  • Notice of appeal deemed filed within thirty day limitation period for Divorce Act matters
  • Appeal Book to include transcript of the one day hearing and transcript of relevant reasons for decision, in particular Paquette J.'s March 2011 reasons