Picture
Picture
Name and Title
Marlin J. Horst
Partner
Partner
Year of Call

1989 (Ontario)
1997 (Bermuda)

Memberships
  • Canadian Bar Association
  • Ontario Bar Association
  • American Bar Association
Publications
Description

Marlin Horst head shot

Testators can head off the threat of an estate dispute by explaining decisions to family members before death, says Toronto corporate and estates lawyer Marlin Horst.

“The worst situation is where someone passes away, and the family is shocked by the contents of the will,” says Horst, a partner with Shibley Righton LLP. “It shouldn’t be that way, but it’s that lack of communication that leads to so many family disputes.”

A recent survey carried out by TD Wealth identified family conflict as the biggest threat to estate planning, with almost half — 46 per cent — of respondents claiming it was their biggest worry. That figure was almost double any other concern, with market volatility and tax reform trailing behind at 24 per cent and 14 per cent respectively.

Digging even deeper into the issue of family conflict, 30 per cent of respondents cited beneficiary designation as the biggest point of contention. Other leading causes of conflict were non-communication and blended families, according to the survey.

The results come as no surprise to Horst, who advises his clients to forewarn family members about any decisions that depart from the norm.

“There are a few assumptions made in families that will not always hold true,” he tells AdvocateDaily.com. “So when a client wants to give a large portion to charity or differing amounts to their children, I ask them to think long and hard about it, and then to explain to their children what is going to happen and why.”

According to Horst, parents will frequently have understandable reasons for differential treatment of their children in a will, and he says the simple act of disclosing them offers a release valve for any developing sibling resentment.

“Parents may base the allocation on the actual or perceived financial need of each child,” he says.

But even equal treatment among children is no guarantee of smooth estate administration, especially in cases where one sibling feels they are more deserving than the others.

“It’s not unusual for the bulk of caregiving responsibilities for elderly parents to fall on one child, so if they get the same share as siblings who did nothing, that can cause strife, even though it’s a typical way to divide an estate,” Horst explains.

He says another common gripe can see bereaved family members divided along generational lines when testators make their bequests to their grandchildren rather than their direct offspring.

“It comes up more often in wealthier families, but the children of the deceased are offended because they see it as an indictment of their ability to be good stewards of the family wealth,” Horst says.

While he acknowledges some estate disputes are unavoidable, he says the chances are reduced when testators are open about their intentions.

“Communication is key in my mind,” Horst says. “At the same time, estate litigation is one of the fastest-growing areas of the law, and we’re going to be seeing a lot of movement in the coming years as the aging Baby Boomer generation — the wealthiest to ever live — transfer their assets to their children.”

 

 

Date_Published
2019-11-18
Description

Marlin Horst head shot

Dying without a will is a selfish decision that can add financial hardship to families suffering with grief, legal experts say.

“When you don’t do anything, and there is a problem, you’re leaving it to somebody else to solve the problem, and that’s no kindness to the people that are grieving a person’s death,” says David Freedman, associate law professor at Queen’s University.

More than half of Canadians don’t have wills. Some people don’t like considering their death, while others carry misconceptions about how their estate will be distributed.

Among the big errors is assuming that all assets will go to the surviving spouse if there are children.

There’s no guarantee that will be the case anywhere in Canada. Provincial rules vary, with some allocating the first $200,000 or $300,000 to spouses, while others pass along one-third of the estate when there are children.

Common-law spouses can wind up with nothing in Ontario, Quebec, New Brunswick, Newfoundland and Labrador, and Nova Scotia, although they can be named beneficiaries outside the will for RRSPs, TFSAs or life insurance.

In Quebec, common-law couples have the same rights as those who are married by entering into civil unions.

The law says those without a will have died “intestate” with no instructions as to how their property should be divided and distributed.

That can put beneficiaries through a wild and costly maze involving the courts that can cause family friction and ill will.

“If you care about any people while you’re alive to leave them without a will you’re leaving people with such a mess,” says Tim Hewson, president of Legalwills.ca, an online service available in Canada outside Quebec.

Failing to have someone in charge of the estate can tear families apart, he said in an interview.

“Families who have previously got along just fine, if there’s no process, theres nobody in charge, then that can cause a lot of animosity and acrimony in families.”

In an interview with AdvocateDaily.com, Toronto wills and estate lawyer Marlin Horst says, it’s not really surprising” that so many people have put off the task.

“People generally do not want to consider their own mortality,” he says. “In particular, younger people do not believe it is an issue.”

Horst, a partner with Shibley Righton LLP, says the issue becomes more complicated in the case of blended families.

“If a person dies intestate and they are part of a blended family it becomes increasingly difficult to determine how the assets will be divided, Horst says. “For example, are stepchildren dependents? The result may not be at all what the people involved thought would happen.

“In the modern world, the blended family issue is very important, and the law has not really caught up with that,” says Horst.

Having a will makes it simpler and less expensive to settle the estate and avoid the family arguments that sometimes end up in court, says Quebec notary Benoit Rivet.

“A lot of times, family problems will resurface with grief, and not having a will only escalates the problem. Because of this, they may end up in court simply because they can’t get along and are arguing about something that happened 30 years ago.”

He added that a notary can also ensure that the proper steps are taken to protect the heirs, who would be responsible if the estate has a lot of debts.

The forced distribution of assets wouldnt likely reflect what most spouses would wish, and could see siblings or distant relatives inherit the estate even if the common-law couple had been in a 20-year relationship.

While Canada Revenue Agency recognizes common-law relationships after 12 months of cohabitation for taxation purposes, some provinces, including Ontario and Quebec, don’t for the purpose of inheritances.

The Western provinces of Alberta, Manitoba and Saskatchewan give common-law spouses some rights to property if they have been living together for two or three years or have a child together, said Sandra Foster, author of You Can’t Take It With You: Common-Sense Estate Planning for Canadians.

“There are many ways to define family, and only in a few provinces have the definitions of family under intestate even moved a little bit forward and become more modern,” she said in an interview.

“It could mean that the common-law spouse could end up with much less than they assumed that they would get.”

The living spouse would be forced to sue the estate for “unjust enrichment” to try to replicate how much of the family property would be available to her or him, said Freedman.

“Things can be done, but youre playing a game of chess where every move is very expensive.”

Meanwhile, an estranged spouse of the deceased would still have a claim to the estate in some provinces since they arent divorced.

The lack of a will can be especially difficult when there are minor children. The court could be called upon to oversee the process and make financial decisions.

In Quebec, the surviving spouse may be entitled to half the value of family patrimony, including residences, furniture, vehicles and pension plans. The spouse would also receive one-third of the estate while two-thirds would be held for the children and be distributed automatically when they reach the age of majority, often not an ideal age to receive a large sum of money.

If the deceased does not have any children, the surviving spouse would receive two-thirds of the estate while one-third would go to the deceaseds parents and siblings.

A family living in Ontario with a surviving spouse and two children would see the spouse receive the first $200,000 and a third of the remaining estate, with the rest split equally between the children.

The guardianship of the children of single parents can be especially traumatic since a judge could have to decide the most appropriate person to care for the children without personally knowing any of the parties.

“So the children may be going to the wrong person,” said Hewson.

Horst says the solution is simple.

 

Date_Published
2019-10-15
Description

Marlin Horst head shotA recent Nova Scotia Supreme Court decision upholds the legal principle that people can leave their estate to whomever they want, provided they are fulfilling their support obligations, says Toronto wills and estate lawyer Marlin Horst.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-09-18
Description

Marlin Horst head shotRemoving the executor of a will is a difficult proposition — and for good reason, says Toronto wills and estate lawyer Marlin Horst.

Horst, a partner with Shibley Righton LLP, says it’s not enough for someone to say, “I dislike the fact that a certain person has been named executor.”

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-08-19
Description

Marlin Horst head shotFailing to fulfil your obligations in a divorce settlement can be costly, even after you pass away, says Toronto wills and estate lawyer Marlin Horst.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-07-05
Description

Marlin Horst head shotPeople who put down a deposit for a property on behalf of a company that is not yet incorporated could lose that money if the buyer pulls out of the deal, says Toronto corporate lawyer Marlin Horst.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-05-15
Description

Marlin Horst head shotA Canadian Securities Administrators’ (CSA) plan to increase oversight of syndicated mortgages is an effort to protect ‘unsophisticated’ investors from risk, Toronto corporate lawyer Marlin Horst tells The Lawyer's Daily.

The CSA has issued a call for comments on proposed amendments that were first suggested in March 2018, The Lawyer's Daily reports.

The council for the provincial and territorial securities regulators indicates the changes will harmonize a regulatory framework for syndicated mortgage investments (SMI) and increase safeguards for investors, the publication reports.

An SMI is a way of funding commercial or residential developments with multiple investors putting their money together to target large-scale real estate projects, The Lawyer's Daily reports, adding the investment is a mortgage registered against title to the property being developed.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-04-10
Description

Marlin Horst head shotWhen someone dies with a life insurance policy listing a clear beneficiary, anyone with a dispute should have solid evidence to support their argument, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

Horst, partner with Shibley Righton LLP, cites a recent Ontario Court of Appeal case to illustrate his point.

Court documents show that in 2014, two men opened a jewelry store in London, Ont. As part of their business arrangement, they took out a life insurance policy on each other, with the company paying the premium. One of them died 16 months later, leaving the partner named as the sole beneficiary of a $250,000 policy.

The estate of the deceased partner, with the wife acting as trustee, disputed that payment. The judgment notes that she claimed that her husband verbally told her she would receive the life insurance money if he died. She also pointed to a handwritten note made by the insurance agent and attached to the policy, concerning a discussion between the two business partners about having a buy/sell agreement.

Horst explains that a buy/sell agreement stipulates that if one of the partners dies, the other one must use the insurance money to buy out the shares of the deceased shareholder. In this case, however, he says the buy/sell provision was not a formal part of the shareholder agreement.”

Instead, the policy simply named the partner as the beneficiary, without stipulating that he had to use the insurance money to buy out the shares from his former partner.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story
.


Date_Published
2019-03-21
Description

Marlin Horst head shotA former telecommunication executive’s attempt to shield family properties from his bankruptcy proceedings provides a textbook example of a sham trust, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

In a recent decision, an Ontario Superior Court judge ruled the trusts holding a farm and cottage for the benefit of the man’s children and stepchildren were void, relying in part on expert evidence that showed the font used in the text of the trust did not exist at the time he claimed to have drawn them up.

But Horst, partner with Shibley Righton LLP, says the font discrepancy was just the “icing on the cake” for the successful trustee in bankruptcy, whose motion to have the bankrupt’s interest in the properties declared assets of the estate — and therefore available to creditors — was granted.

“There were so many other things that pointed to the trust being a sham, and the decision lays those out in great detail,” he says. “There was very little evidence to suggest that the property was ever held genuinely in trust, and I think the result would have been the same, even without the font element.”

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2019-02-12
Description

Marlin Horst head shotSuccession planning can ease the transition when the time comes to transfer ownership of family-run businesses, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

A recent report commissioned by the Canadian Federation of Independent Businesses (CFIB) found that just eight per cent of small and medium enterprise (SME) owners had a formal succession plan in place.

Around 40 per cent of the 2,500 respondents to the CFIB survey had an informal plan in place but more than half of the business owners had no plan at all for the life of the company after their departure.  

That was despite evidence that 47 per cent of owners intended to leave their businesses within five years, and almost three-quarters wanted to be out within a decade. In addition, around 62 per cent intended to rely on the proceeds of an eventual sale to partially fund their retirement.

Horst, partner with Shibley Righton LLP, says it’s never too early to start planning a succession, but adds that he’s not surprised by the results of the survey. 

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story
.


Date_Published
2019-01-23
Description

Marlin Horst head shotExecutors should make sure beneficiaries are fully informed before taking compensation from the estate according to a recent decision, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com

The case involved a disputed passing of accounts by a lawyer acting as an estate trustee on a $3-million estate.

The lawyer, who spent 10 years without formally passing accounts, argued beneficiaries’ objections to actions more than two years old should be struck out under the Limitations Act.

However, a unanimous panel of appeal court judges, sitting as the Divisional Court, upheld a lower court judge’s ruling in favour of the beneficiaries.

“By filing a notice of objection to accounts in response to an estate trustee’s application to pass accounts, a beneficiary is not commencing a proceeding in respect of a claim within the meaning of s. 4 of the Limitations Act,” Appeal Court Justice David Brown wrote for his colleagues in dismissing the appeal.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story
.


Date_Published
2018-12-21
Description

Marlin Horst head shotA defrauded corporate lender who unsuccessfully tried to sue the government to cover $1.8 million in losses was always facing an uphill struggle, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

A better strategy for the lender would have been to conduct more stringent due diligence at the outset rather than suing the Crown after the fact, says Horst, partner with Shibley Righton LLP.

The Ontario Court of Appeal matter involved a lender who advanced $1.8 million in mortgages to a man on the grounds he was the sole owner and officer of a company. The loans were advanced after the lender checked the Ministry of Government and Consumer Services' corporate registry and found the man was listed as a director and officer.

However, it transpired that this was a complete fabrication and the man had merely filed a change order to the registration with no authority whatsoever.

The appellant argued that the ministry owed a duty of care to reasonably ensure the accuracy and reliability of the information it collected, maintained and disseminated for a fee when it knew or ought to have known that the appellant would rely upon such information.  

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-11-26
Description

Marlin Horst head shotIt can be difficult for family business partners to keep emotions separate from management and operations, particularly when one generation is passing control off to the next, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

“Family business disputes are not as uncommon as people think, especially when you have a strong founder passing off an empire to the next generation,” says Horst, a partner with Shibley Righton LLP.

Earlier this month, an Ontario business magnate and his wife launched a lawsuit claiming their daughter, two grandchildren and others are allegedly mismanaging the family's assets and trust funds. The Canadian Press reports the suit, which has not been proven in court, seeks more than $500 million in damages.

In their statement of claim, the parents accuse their daughter and others of allegedly "having undertaken a series of covert and unlawful actions" that have been contrary to the best interests of other family members. As well, they claim their daughter led an extravagant lifestyle that has allegedly drained the company in excess of $70 million.

His daughter has denied the allegations stating, “Family relationships within a business can be challenging. My children and I love my father. However, his allegations are untrue and we will be responding formally to the statement of claim in the normal course of the court process,” the newswire reports.

Horst says a common point of friction in some companies is when elders back out to let the next generation run the family business.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-10-29
Description

Marlin Horst head shotA recent Ontario Court of Appeal ruling on interest disclosure is likely a relief to lenders as it confirms that a small violation of s. 4 of the Interest Act will not impact all interest payable under a loan agreement, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

The case centred around a number of loans made by one party to another — although the respondent party defaulted, it disputed the amount of interest owing.

Specifically, the respondent claimed that term in the loan agreement, requiring payment of a .003 per cent discount fee of the outstanding loans on the repayment date and every day thereafter while it remains outstanding, failed to comply with s. 4 of the Interest Act.

The Act requires that any written agreement for the payment of interest at a rate or percentage per day, week, month or any period less than one year must contain “an express statement of the yearly rate or percentage of interest to which the other rate or percentage is equivalent.”

“Section 4 provides that where an agreement fails to comply with this requirement, ‘no interest exceeding the rate or percentage of five per cent per annum shall be chargeable,’” notes the court.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-09-25
Description

Marlin Horst head shotA report that suggests the federal government could collect $2 billion annually if it implements a tax on inheritances of $5 million or more doesn’t take some unintended consequences into account, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

“One of the problems with an inheritance tax is that the very wealthy will structure their finances in such a way that they don't have to pay it,” says Horst, a partner with Shibley Righton LLP. “People will transfer everything to their heirs before they die or they will set up family trusts — money that will likely go offshore.”

The Canadian Centre for Policy Alternatives (CCPA) report looked at inequalities in wealth between those on the extreme high end in Canada and everybody else. Economist David Macdonald told CBC News the 87 wealthiest families in the country owned a collective $259 billion at the end of last year.

“He contrasted that with the numbers for the median Canadian family, which saw its net worth increase by just 15 per cent over the same time period — rising to $295,100 from $257,200,” the article states.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-08-23
Description

Marlin Horst head shotProponents pushing blockchain technology to create mortgages are putting the cart before the horse, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

Horst, a partner with Shibley Righton LLP, says blockchain — best known as the encryption technology behind Bitcoin — is essentially a digital ledger that can be used for many other purposes beyond currency, but he’s wary of a scheme being promoted in Bermuda to create mortgages which investors could then purchase fractionally.

The Financial Post reports that the company would use local financial professionals to run “mortgage hubs” that would evaluate and underwrite them, dividing each property transaction into 100,000 Fractional Mortgage Share (FMS) units that could then be listed on the company’s blockchain-based exchange. Investors would purchase an FMS using blockchain-based tokens and would harvest principal and interest payments from the property’s owner each month.

In some cases the mortgages might also be crowdfunded with smaller fractions for investors but its setup is poorly timed and fraught with potential problems, Horst cautions.

While these mortgages are not available in Canada, promoters of the concept say it could be set up in any jurisdiction which raises a red flag, he says.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-07-16
Description

Marlin Horst head shotSandbagging reflects poorly on all parties to a transaction, Toronto corporate lawyer Marlin Horst tells AdvocateDaily.com.

Horst, a partner with Shibley Righton LLP, explains that the practice arises in mergers and acquisitions when a buyer becomes aware that the seller will be unable to meet all the representations and warranties made in the agreement.

That allows the purchaser to close the deal with the intention of later suing the vendor in court for damages related to the known deficiencies since contracts normally provide indemnities for buyers in the event promises can’t be met.

Horst says examples of sandbagging are relatively rare in Canada, but the issue is growing as parties on both sides take the risk of an episode into consideration when completing transactions. Nevertheless, he says the trend is concerning.

“If vendors are making representations and warranties that are not correct, then it means they’re not doing their own internal due diligence properly,” Horst says. “If the buyer discovers something that the vendor itself doesn’t know, it shows a lack of knowledge about their own business.”

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story
.

Date_Published
2018-06-19
Description

Marlin Horst head shotProposed rules around syndicated mortgage investments (SMI) will help “weed out” those who are taking advantage of unsophisticated investors, Toronto corporate and commercial lawyer Marlin Horst tells The Lawyer’s Daily.

An SMI “is a method of funding commercial or residential developments where two or more people pool their money to invest in large-scale real estate projects,” the article states. “The investment is a mortgage registered against title to the property that is being developed.”

The legal publication notes the Financial Services Commission of Ontario has issued more than $1 million in fines against companies involved in the SMI market and the Canadian Securities Administrators (CSA) has put forward proposed amendments in an attempt to harmonize the regulatory framework across Canada.

Horst, a partner with Shibley Righton LLP, says the syndicated mortgage market is “ripe for taking advantage of less sophisticated investors,” who think a mortgage is a good, safe investment.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-03-22
Description

Marlin Horst head shotWhile a Mareva injunction is an effective tool to stop another party from dissipating their assets, a recent Ontario Court of Appeal (OCA) ruling confirms that it will not keep a creditor from being able to access those funds, Toronto corporate and commercial lawyer Marlin Horst tells AdvocateDaily.com.

In the case, one company was granted a Mareva injunction against another. However, a creditor later applied to vary the injunction, so that it could seize money in the second company’s account under a properly issued writ of seizure and sale.

While the company appealed the motion judge’s decision to vary the Mareva injunction, the OCA dismissed the appeal, noting: “... the appellant’s Mareva injunction gives it no proprietary interest in the funds in 701. It has been unable to date to prove or establish its claim in respect to account number 701. There is no basis for the third party, [the creditor], to suffer prejudice as a result.”

Horst, a partner with Shibley Righton LLP, says the ruling shows the courts will not stand in the way of a party who has received judgment from executing against funds in a bank account, even if a Mareva injunction is in place.

In addition, he says, if a party had been given security over their assets, a Mareva injunction would not stop the secured party from having the right to realize on those assets.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-02-21
Description

Marlin Horst head shotCredit bidders will have to pay close attention to the wording of purchase agreements and guarantees after Ontario’s top court reduced the amount a company president owed from US$3 million to just US$250,000, says Toronto corporate and commercial lawyer Marlin Horst.

The defendant in the case provided a personal guarantee for corporate indebtedness, limited at $3 million, as part of a financing agreement with a bank. When the company’s debt was purchased by the plaintiff — a distressed debt lender — the guarantee was part of the deal.  

After the company defaulted on its loans, the lender ultimately purchased its assets with a credit bid worth $34 million, $3 million less than the $37 million the defendant was owed by the company.

A motion judge ordered the former president to pay the full difference plus interest due to the guarantee, but a unanimous panel of Ontario’s Court of Appeal overturned the decision and reduced his liability to $250,000.  

The court ruled that there was no evidence that $2.75-million worth of facility and forbearance fees, which were specifically excluded from the guarantee, had been included in the extinguished portion of the debt.

This is an excerpt from an article that appeared on AdvocateDaily.com.

Please click here to read the rest of the story.

Date_Published
2018-01-12
Experience
More About
BIO

Marlin Horst is a partner with Shibley Righton LLP. His experience involves acting on behalf of corporations in a range of industries including financial services, where his practice encompasses all types of lending including syndicated, senior, subordinated, asset-based and project finance.

In addition to his corporate practice Marlin practices in the area of charities and estate planning and administration.  He has experience acting for high net worth individuals as well as other entrepreneurs and business owners.  Marlin has experience acting on behalf of registered charities and other not for profit entities.

Marlin's corporate and lending experience includes transactions in financial services, manufacturing, hospitality, retail, services, energy, mining and private equity industries. He also has expertise in restructuring transactions, acting on behalf of both creditors and debtors. Marlin regularly advises on mergers and acquisitions, mutual funds, real estate, general corporate and commercial transactions as well as venture capital/private equity transactions. Prior to joining Shibley Righton LLP, he practised corporate and finance law in both Toronto and Bermuda.

Marlin was a sessional professor at Queen's University Law School where he tought courses on Commercial Law and the Personal Property Security Act for 10 years.  In addition, he was an adjunct professor of Banking Law at the University of Western Ontario for over ten years.

Outside of the practice of law Marlin is a director and President of FOCA (Federation of Ontario Cottagers Association).  Marlin has also sat on the board of a number of charities and not for profit entities.

Contact Information

T: 416.214.5211
F: 416.214.5411
E: marlin.horst@shibleyrighton.com

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Education

Cambridge University, LL.M., 1987
University of Western Ontario, LL.B., 1986, B.A. 1983

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