Production Of Documents From Court-Appointed Receivers


Originally published in International Law Office, January 2013:

In its recent decision in SA Capital Growth Corp v Mander Estate the Ontario Court of Appeal considered whether the appellant, who was facing proceedings before the Ontario Securities Commission (OSC), was entitled to production of documents and information from the court-appointed receiver that had been appointed to investigate a Ponzi scheme in which the appellant was allegedly involved. Justice Pattillo, the application judge, ordered production of some, but not all, of the documents sought by the appellant, Peter Sbaraglia. Sbaraglia appealed, seeking further production, while the receiver cross-appealed, arguing that no production should have been ordered.

The Ontario Court of Appeal dismissed Sbaraglia's appeal and granted the receiver's cross-appeal. In doing so, the court considered two important issues...

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