Cemeka Alana Douglas

The applicant sought a bail review under s. 520 of the Criminal Code after being detained on secondary grounds.

The court found a material change in circumstances due to charge withdrawals/amendments and new disclosure, allowing a fresh consideration of bail.

However, the proposed new release plan, including a new surety, was deemed insufficient to mitigate the substantial likelihood of re-offending, given the seriousness and repetition of the charges, the applicant's history of non-compliance with release orders, and the surety's lack of insight and inadequate supervision plan.

The court also noted an error by the original Justice of the Peace in failing to consider the tertiary ground, but ultimately dismissed the bail review application, affirming continued detention on secondary grounds.

The plaintiffs commenced two actions arising from the purchase of a property with structural issues: one against Stewart Title for breach of title insurance contract and a "tort action" against multiple parties (vendors, home inspector, township, contractors) for property defects.

Stewart Title moved to consolidate the two actions.

The plaintiffs and two defendants from the tort action (the vendors) opposed consolidation, preferring the actions be heard together or one after the other.

The court, applying Rule 6.01 of the Rules of Civil Procedure, conducted a costs/benefits analysis.

It rejected the notion of an elevated onus for consolidation and found that ordering the actions to be heard together, with common discoveries and pre-trial, best served efficiency and fairness.

This decision was primarily to avoid significant costs and delays associated with potential crossclaims and pleadings disputes that full consolidation would trigger, particularly regarding Stewart Title's potential subrogation claims.

The motion for consolidation was dismissed, and an order for the actions to be tried together was granted with specific directions for common pre-trial and discoveries.