Court File and Parties

Court File Nos.:

• CV-22-00692240-0000
• CV-22-00692296-0000
• CV-23-0000614-0000
• CV-23-00700626-0000
• CV-23-00700570-0000

Date: November 4, 2025

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Vanessa Ibe, Rosenbaum & Ibe LLP, et al.[1]

Before: L. Brownstone J.

Counsel:

• William M. Sharpe and Anumeet Toor, for the Plaintiffs
• Vadim Kats, for the defendant Andrei Borlokov

Heard: In writing

Endorsement

Introduction

[1] Martin Rosenbaum and Vanessa Ibe were law partners, practicing as Rosenbaum & Ibe LLP ("the Firm"). In about August 2022, Mr. Rosenbaum discovered that Ms. Ibe had misappropriated and misapplied monies in the Firm's mixed trust account.

[2] In the wake of Ms. Ibe's actions, a plethora of litigation was commenced. I have been case managing the litigation for over a year.

[3] Some of the litigation is in the form of clients of the Firm suing Ms. Ibe and the Firm (the negligence actions). Those actions, while part of the case management portfolio of claims, are not the subject of this decision and are unaffected by it. The same applies to an action Mr. Rosenbaum and the Firm have commenced against LAWPRO.

[4] In addition to these claims, between December 2022 and December 2023, Mr. Rosenbaum and his professional law corporation issued five actions against some or all of Ms. Ibe, the Firm, clients, and former clients whose trust funds were dealt with inappropriately by Ms. Ibe. He refers to these claims as "recovery actions" or "protective actions"[2]. Mr. Rosenbaum and his professional corporation are the plaintiffs in each action. For concision, I refer to the plaintiffs often simply as Mr. Rosenbaum, but it is meant to capture both Mr. Rosenbaum and his corporation.

The "Protective Actions"

[5] The five proceedings that are the subject of this endorsement can be summarized as follows.

1) CV-22-00692240-0000

[6] In this action, Mr. Rosenbaum and his professional corporation sued the Firm, Ms. Ibe, and three individuals – Glenn Dodds, Dorothy Dodds, and Andrei Bornovolokov. Mr. Rosenbaum also named "Recipients 1 to 5" as defendants, persons whose identities are unknown but whom he believes received trust monies to which they were not entitled. Mr. Rosenbaum seeks, among other things, a declaration that Mr. Bornovolokov received monies from the Firm as trustee for the benefit of Glenn and Dorothy Dodds.

[7] In brief, the claim alleges that Ms. Ibe was retained by Mr. Bornovolokov in two proceedings, and by Glenn Dodds in connection with the sale of the matrimonial home he shared with Dorothy Dodds. Ms. Ibe is alleged to have wrongfully represented to Mr. Bornovolokov that she had received judgment, a forged version of which she provided to him, in one of his claims. She is alleged to have used the Dodds's trust monies to pay Mr. Bornovolokov the funds to which he was "entitled" under the "judgment". Mr. Rosenbaum seeks return of Mr. Bornovolokov's monies, "for the benefit of Glenn and Dorothy Dodds".

[8] Mr. Bornovolokov has defended the action, crossclaimed against Ms. Ibe and the Firm, and counterclaimed against both plaintiffs. He seeks, among other things, damages and repayment of legal fees and disbursements. He claims, among other things, that he has lost the right to pursue and recover damages in his actions, the second of which Ms. Ibe had wrongly advised would be proceeding in September 2022.

[9] Mr. Bornovolokov submits that the action, crossclaim, and counterclaim should all be stayed. Mr. Rosenbaum submits that no claims should be stayed. However, if the court decides to stay the main action, he agrees that Mr. Bornovolokov's crossclaim and counterclaim should also be stayed.

2) CV-22-00692296-0000

[10] In this claim, Mr. Rosenbaum sues Ms. Ibe, the Firm, Glenn Dodds, Jesus de Francia, "Clients 1-47 inclusive", Niam Pharmaceuticals Inc., BJM Products Inc., Fuel 218 Inc. and "Recipients 1-9 inclusive".

[11] The claim alleges that Ms. Ibe acted for plaintiffs Fuel 218 in one action and Niam Pharmaceuticals in a second. In the Niam action, it is alleged that the defendants brought a summary judgment motion which Ms. Ibe did not defend. She agreed to pay $45,000 in costs on Niam's behalf. She used trust funds of Jesus DeFrancia and Luce Boire to pay those costs (although Luce Boire is referred to as a defendant in the pleading, she is not a named defendant in this proceeding. She is named in CV-23-00700626-0000).

[12] It is further alleged that the Firm received about $2,200,000 in trust from the sale of the Dodds' matrimonial home. Ms. Ibe falsely told Fuel 218 that its action had been resolved in its favour, and wrongly caused just over $175,000 to be used to pay Fuel 218's affiliated company, BJM Products Inc. The Dodds' funds were said to have been used to pay BJM.

3) CV-23-0000614-0000

[13] In this action, Mr. Rosenbaum sues the Firm, Ms. Ibe, Magnificat Charismatic Prayer Community, Regina Mundi Corp, 42 other named defendants, "Clients 1-3" and "Recipients 1-5". The claim seeks, among other things, an order for equitable tracing of funds misappropriated and misapplied by Ms. Ibe, and declarations that some parties hold funds in trust for the plaintiffs' benefit.

[14] Other relief is sought against specific defendants alleged to be wrongful recipients of trust monies. It is alleged that Ms. Ibe forged a judgment that found that the affairs of Regina Mundi Corp. and Magnificat Charismatic Prayer Community had been oppressive to its plaintiff shareholders. The judgment purported to reverse the transfer of property from Regina Mundi to Magnificat. Ms. Ibe purported to take further steps with respect to the property in issue. She then is stated to have wrongfully caused other clients' trust funds to be withdrawn to make payments, to which they were not legally entitled, to Regina Mundi and its shareholders.

4) CV-23-00700626-0000

[15] Here, Mr. Rosenbaum named Ms. Ibe, the Firm and all identified remaining client beneficiaries of Rosenbaum & Ibe LLP's mixed trust account. There are about 136 named defendants named in this action.

[16] Some of the defendants are said to be "victim trust account holders", said to be named in the action so that they are bound by determinations in the action. Many are said to be "hybrid parties", both victims and wrongful recipients. The claim alleges certain clients wrongly received funds that Ms. Ibe had misappropriated from others. It states that all clients are adversely affected, given their undivided interest in the Firm's mixed trust account.

5) CV-23-00700570-0000

[17] Mr. Rosenbaum does not specifically refer to this claim in his submissions, other than the appendix. In this action, he sues Ms. Ibe, the Firm, Mekker Construction Ltd., Annie Yilmaz, Aykut Yilmaz, Gabriella Moscatello, Evan Braun, Robin Dussart, John Barroso, June Liddell, Lise Varette, Stiffra Armamento, Recipient 1, Recipient 2, Recipient 3, Recipient 4, Recipient 5, Recipients 6 - 15, David Guy, Blair Laursen, SDM Construction Inc., Clients 1- 3 and Clients 4 to 160.

[18] The claim alleges that Ms. Ibe falsely represented to Mekker Construction that the Firm had obtained default judgment on its behalf, wrongly gave funds to Annie and Aykut Yilmaz, clients in other litigation, wrongly took money from Evan Braun to pay Gabriella Moscatello, took funds belonging to Matthew Garrett and Ms. Moscatello and paid them to other clients, wrongly dealt with Ms. Liddell's funds meant for a property purchase and sale, wrongly gave funds to Lise Varette, wrongly failed to discharge a mortgage on Ms. Armamento's property, wrongly took money from David Guy's account to pay Dorothy Dodds, Regina Mundi, and Keven Holmes, and took money from SDM Construction to pay Ms. Ibe's own debt.

Proceedings to Date

[19] From the outset of the case management proceedings, the court's focus in the "recovery actions" has been on getting a clear picture of who was alleged to owe or be owed how much money, and on reducing the number of parties to those actions.

[20] Many clients of the Firm wrote memoranda to the court objecting to incurring legal fees to defend an action when they are named as victims and asking to be let out of the actions. At least one memorandum asked the court to dismiss the claim under rule 2.1. Another stated "We are overwhelmed by the number of documents sent to our residence and the daunting task of representing ourselves as "defendants" when we have done nothing but have our savings taken from us."

[21] LAWPRO has been involved since they were advised of the defalcations in August 2022 and has been present throughout the case management proceedings.

[22] At the first case management conference in September 2024, some defendants expressed their frustration at their inability to be provided with precise information on what funds were said to be owed by or owing to them. I required all the victim trust account holders to be advised of the amounts they were owed within a week.

[23] At the next case conference in November, about 15 defendants were released from the litigation. Some parties who had been originally told they were victim account holders and named as such in the pleadings were told they were not victims, but that they owed the Firm an undisclosed sum of money. No one who was alleged to owe money was told the amount they were said to owe. They had been "rebuffed" when they asked for that information. I repeated to plaintiffs' counsel that in the absence of information about the amount of money at issue, it was impossible for parties to make choices about what steps they wished to take in the litigation. Nor were they in a position to provide a "submission of rights", a process Mr. Rosenbaum has repeatedly suggested be followed. The defendants asked for another order to ensure they received the required information. I ordered that full information be provided by November 20, 2024. The next case conference was set for December 11, 2024, and I indicated that that conference would begin with identifying defendants against whom the litigation was to be discontinued or dismissed.

[24] Still at the December case conference, some defendants advised they had not been provided the ordered information. Issues of potential inaccuracy with the accounting were raised by LAWPRO. The Court raised the issue of possibly staying the protective actions under r. 2.1.

[25] Shortly thereafter, the plaintiffs advised they wished to bring a motion for me to recuse myself based on an apprehension of bias. The next conference was used to timetable that motion. I dismissed that motion for reasons reported at Rosenbaum v. Ibe, 2025 ONSC 3100.

[26] At the case conference following the release of that decision, I ordered Mr. Rosenbaum to provide a list with each party's name and balance owed or owing. An updated chart was ordered at the next case conference. Mr. Rosenbaum was also ordered to respond to LAWPRO's queries about differences between his last chart and the forensic review.

[27] Efforts at obtaining a full accounting of monies that are owed and owing have been underway and are the subject of other endorsements. Lack of clarity on this issue remains an issue to this day. My endorsement of July 24, 2025, stated in part as follows:

Unfortunately, many individuals continue to receive conflicting information about amounts owed or owing. Many individuals continue to seek clarity and an end to their involvement in this litigation, as their time and expense continues to outweigh what they believe are amounts owed or owing. I had hoped the directions to date would have resolved more of these issues than it has.

In particular, the defendants Dodds, Liddell, Barosso, Duguay, Duarte, Watkinson, Cruz-Fuentes, and Guy today raised these issues and concern about moving the matter forward. There are undoubtedly others in the same situation. … Those issues will be a priority moving forward.

[28] In my endorsement from the next case conference held in September 2025 I noted:

There remain discrepancies in respect of the amounts owed and owing in Mr. Rosenbaum's forensic reports and that of LawPro. Mr. Rosenbaum will provide a complete response to LawPro's questions by November 7, 2025.

[29] I also advised Mr. Rosenbaum that the court was considering staying the "protective actions" in whole or in part, at least on a temporary basis under s. 106 of the Courts of Justice Act, RSO 1990, c. C. 43. This would enable former clients to be relieved of the burdens of responding to the litigation at least while the LAWPRO process is underway and funds are being, or may be, accessed. If, after the usual processes are completed, there is a need for some or all of the litigation to continue, a motion to lift the stay could be brought. I asked Mr. Rosenbaum to provide submissions on this potential course of action.

Law and Analysis

[30] Section 106 of the Courts of Justice Act provides:

A court, on its own initiative or on motion by any person, whether or not a party, may stay any proceeding in the court on such terms as are considered just.

[31] Mr. Rosenbaum rightly points out that the circumstances in which the court may appropriately do so on its own motion are rare. The court must be satisfied, on a high onus, that to continue the action would be unjust in that it would be oppressive, vexatious, or an abuse of the court's process. It must also be satisfied that the stay would not cause an injustice to the plaintiff: Yaiguaje v. Chevron Corporation, 2013 ONCA 758 at paras. 54-55; aff'd 2015 SCC 42, [2015] 3 SCR 69.

[32] Mr. Rosenbaum argues that the actions do not attempt to relitigate settled issues, and therefore there is no risk that allowing the litigation to proceed would violate principles like judicial economy, consistency, finality, and the integrity of the administration of justice: Business Development Bank of Canada v. Astoria Organic Matters Ltd., 2019 ONSC 6557 at paras. 45-46. Nor, he argues, are the proceedings an attack on prior findings, which would constitute an abuse of process. For this proposition he relies on Javid v. Javid, 2023 ONSC 6719.

[33] Mr. Rosenbaum also notes that he is not proceeding in breach of a settlement agreement or undertaking, actions that have been held to be an abuse of process: Sinclair-Cockburn Insurance Brokers Ltd. v. Richards, 61 O.R. (3d) 105. Nor has there been undue delay or loss or destruction of documents.

[34] However, multiplicity of proceedings, re-litigation, breach of a settlement agreement and collateral attack are but examples of abuses of process. These examples do not form a closed list of bases upon which proceedings may be stayed. In Javid, Merritt J. helpfully explains at para. 38:

Abuse of process is a discretionary principle. It is used to bar proceedings that are inconsistent with the objectives of public policy. It engages the inherent power of the court to prevent a misuse of its procedure in a way that is manifestly unfair or brings the administration of justice into disrepute. The doctrine is applied … where litigation is an attempt to relitigate a claim which the court has already determined. There is a degree of overlap between the terms frivolous, vexatious and abuse of process [citations omitted].

[35] Mr. Rosenbaum argues that there is good reason for the actions to proceed. He notes that he asked LAWPRO to commence these actions. LAWPRO declined and told him he was doing so at his own expense and risk. He argues that all the clients have an undivided common interest in the mixed trust account. He states that he therefore has an obligation as trustee for the client beneficiaries of the Firm's trust account to account for, protect and recover funds.

[36] Mr. Rosenbaum argues that he has a duty to the Firm's client beneficiaries of trust funds as a successor trustee. He states that his duties are to a) account for, protect and recover misappropriated and misapplied trust monies; b) protect against the expiry of otherwise potentially applicable limitations periods; c) protect LAWPRO's rights of subrogation if it is determined LAWPRO has obligations to indemnify the Plaintiffs; and d) pursue the return of trust funds from persons or entities who received trust funds wrongfully paid to them by Ms. Ibe.

[37] Mr. Rosenbaum acknowledges that there no known cases in which a law partner of a defalcating lawyer has brought such claims. However, he relies on Law Society of Upper Canada v. Toronto-Dominion Bank, 42 O.R. (3d) 257 (Ont. CA) as support for the commencement of the claims.

[38] In TD Bank, a lawyer had misappropriated funds from his mixed trust account. Because the beneficiaries' claims exceeded the balance of the account, the court held that the shortfall would be divided in proportion to their respective interest in the funds.

[39] Even assuming that proposition will ultimately apply to the beneficiaries of the Firm's mixed trust account, the case provides no requirement for Mr. Rosenbaum to sue the beneficiaries. There is not yet a known shortfall. Ms. Ibe and the Firm are insured. There may be other compensation available. The remaining funds in the mixed trust account are preserved by the Law Society.

[40] Mr. Rosenbaum proposed throughout that the parties participate in a submission of rights process as contemplated in the estates rule 75.07 and form 75.10. I have repeatedly explained that, even if such a process were available to the parties, it is impossible for the defendants to make such a submission when there is still no clarity or precision on what funds they are said to owe or be owed.

[41] In the course of case managing the proceedings, the court heard from individual former clients of the Firm who had been named as parties to the litigation. They repeatedly spoke against having to participate in any way, including providing a submission of rights and returning for further conferences. In some cases, they were spending more on counsel to attend the case conference and to communicate with Mr. Rosenbaum's counsel than they were said to owe to or be owed by the Firm. They sought to be released from the litigation. Some victims expressed difficulties getting responses from Mr. Rosenbaum's counsel in their previous efforts to deal with the matter. Several expressed that they had asked and were not aware of what the audit revealed them to be owed.

[42] The onus for action and clarity should not shift to the Firm's victims through a process akin to a submission of rights.

[43] This is indeed a series of extraordinary cases. Neither the plaintiffs, nor LAWPRO, nor the court, is aware of any similar course of litigation pursued by an insured lawyer. As the case management judge, I have significant concerns about the lack of progress in the protective actions. Seven case conferences and one bias motion have achieved very little progress in these protective actions. Orders for disclosure have not yielded their desired results.

[44] At the beginning of the case management proceedings, the court adopted a strategy of trying to have unnecessary parties removed from the litigation. It has become more than apparent that this strategy is not working. There remains no clarity on the amounts owing to and ostensibly from many parties.

[45] The parties to the litigation have been lied to and stolen from by their lawyer, Ms. Ibe. On top of that, they have been named as defendants in litigation related to those events. The manner in which this litigation is being conducted is punishing clients who have already suffered at the hands of Ms. Ibe. To allow this to continue is abusive and manifestly unfair.

[46] Mr. Rosenbaum attempts to distinguish between victims and wrongful recipients of trust funds. However, many of the "wrongful recipients" are also victims. In many cases, they lost their right to pursue claims. Their money was taken, they were lied to, and many of them suffered significant consequences as a result thereof.

[47] They are in effect being asked to bear the burden of the wrongdoings of their former counsel, who stood in a fiduciary relationship to them. That cannot continue.

[48] It is clear that the appropriate strategy in the "protective actions" is to adopt the opposite approach from that taken to date - it is to be presumed that the litigation against the parties should not proceed, absent the plaintiffs being able to demonstrate that litigating against the Firm's former clients, or any of them, or inter-related third parties, is an appropriate course of conduct. These parties should not have to be embroiled in litigation unless and until such litigation is shown to be the necessary and appropriate course of action.

[49] Mr. Rosenbaum's claim that his actions are the only available process whereby the client beneficiaries have the possibility of being fully compensated rings hollow. He argues that staying the proceedings will harm the defendants.

[50] I cannot agree. The defendants in the "protective actions" have been clamoring for clarity and for an end to their suffering at the hands of their former counsel. Continuing the litigation would be oppressive, vexatious, and an abuse of the court's process. It is telling that there is no precedent for such litigation. The prejudice to the defendants is obvious. On the other side, it is hard to see the prejudice to Mr. Rosenbaum. He claims to be bringing the actions to protect the Firm's former clients. They do not wish to have his protection. He claims to have spent hundreds of thousands of dollars pursuing the claims. Very little progress has been made in bringing any clarity to his claims. Many people remain unaware of the precise financial value of any claim said to involve them.

[51] Any prejudice to Mr. Rosenbaum is mitigated in two ways. First, his claim against Ms. Ibe, the wrongdoer, is unaffected by this ruling. Second, should he be able to bring clarity to these proceedings he has commenced, and should they become necessary to protect his interests, he may apply to the court for a lifting of the stay.

Order

[52] The five "protective actions" are stayed. If and when the following events occur, the plaintiffs or other parties may move before the court to lift the stay in whole or in part:

a. There is proper evidence available of an amount of money that is owing to the plaintiffs from any specific defendant;

b. Any of the defendants are specifically alleged, with a proper foundation, to have knowingly participated in Ms. Ibe's misconduct to their benefit;

c. The LAWPRO process has concluded or has sufficiently advanced that the plaintiffs can put forth a proper foundation for alleging that specified amounts of money are owing from specific defendants to the plaintiffs.

[53] As a result, the defendants in the five actions covered by this endorsement need not attend further case conferences or other proceedings unless and until a motion is brought to lift the stay of the proceedings. Any such motion will be brought on notice to all affected parties.

L. Brownstone J.

Date: November 4, 2025

Appendix A

CV-22-00692240-0000

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Glenn Dodds, Dorothy Dodds, Rosenbaum & Ibe LLP., Andrei Bornovolokov, Recipient 1, Recipient 2, Recipient 3, Recipient 4, Recipient 5, and Vanessa Ibe, Barrister & Solicitor personally and as former Managing Partner of Rosenbaum & Ibe LLP

CV-22-00692296-0000

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Glenn Dodds, Jesus de Francia, Rosenbaum & Ibe LLP., Clients 1-47 Inclusive, Niam Pharmaceuticals Inc., BJM Products Inc, Fuel 218 Inc., Recipients 1-9 Inclusive

And: Vanessa Ibe, Barrister & Solicitor personally and as former Managing Partner of Rosenbaum & Ibe LLP

CV-23-0000614-0000

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Rosenbaum & Ibe LLP., Vanessa Ibe In her Personal Capacity and as Managing Partner of Rosenbaum & Ibe LLP, Regina Mundi Corp., Magnificat Charismatic Prayer Community, Julia Priagula, Remedios Paguirigan, Charles Gonzales, Manuel Ballasteros, Sandra Masciarelli, Elizabeth Reyes, Amelia de Guzman, Nora Puyo, Luisa Cusi, Teresita Gutierez, Teresita Gonzales, Ananias Cruz a.k.a. Nanette Cruz, Fanny Calucag, Perseverando Carreon a.k.a. Percy Carreon, Felix Jesus Morales, Felix Morales, Besilio G. Spencer, Romeo T. Candido, Amy Hernaez, Gloria Pasildo, Eduardo Tinio Tan, Ernesto Figuracion, Maria Gonsalves, Purita Reyes, Amparo Bumangiag, Besiliza Spencer, Recipient 1, Recipient 2, Recipient 3, Recipient 4, Recipient 5, Guillermo Puyo, SDM Construction Inc., Sanjay Dubey, Charlotte Dugue, Robin Dussart, Blair Larsen a.k.a. Blair Laursen, Greg Watkinson a.k.a. Greg Walkinson, Edy Cruz-Fuentes, Oomer Bachu, Cai-Han Lee a.k.a. Hanson Liis, Robros Investments Inc., Gabriella Moscatello, Matthew Garrett, Lise Varette, 2505619 Ontario Inc., Shazia Khan, Client 1, Client 2 and Client 3

CV-23-00700626-0000

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Vanessa Ibe, Rosenbaum & Ibe LLP, Lise Varrette, Annie Yilmaz, Aykut Yilmaz, John Barroso, Stiffra Armamento, David Guy, Mekker Construction Ltd., Levante Mekker, Eszter Mekker, Dorothy Dodds, Charlotte Dugue, Robin Dussart, Matthew Garrett, Gabriella Moscatello, Evan Braun, Blair Laursen, June Liddell, 2695026 Ontario Corp., Tadeo Sanchez, 2036133 Ontario Ltd., 2505619 Ontario Inc., 2749612 Ontario Inc., Alex Aselstyne, 1198380 Ontario Limited, Albion Holdings Ltd., Michael Amson, Angelo Arvanitakis, Available Roofing and Remodeling Inc., Marc Brathwaite, Suzanne Clarke, John Barroso, BHD Investments Inc., George Dreher, Luce Boire, Carolyn Bowman, Stephen Bowman, James Byers, 1173267 Ontario Inc., Ramona Butt, Michael Cain, Centrotex Foreign Trade Company Limited, Dougal Clark, Margaret Stuart, Charles Cohen, Caitlin Connelly, Trevor William Tomkins, Custom-Pak Inc., Art Dicecco, 2489297 Ontario Inc., DMD Building Systems Corp., Glenn Dodds, Thomas Douglas, Adam Dwek, Fernando Faria, Federacion de Agroexportadores de Honduras, Shane Foran, Fitzroy Fuller, Chad Geense, Seyedmohammadali Ghazitabatabai, Aaron Goodman, Dan Grigorayeb, Sandeep Gupta, Greg Watkinson, Edy Lorena Cruz-Fuentes, Keith Hall, Ana Harriott, Brad Hillis, Misti Holmes, Kevin Holmes, Howar Equipment Inc., Nancy Iadeluca, IFG International Financial Group, Adil Khalfan, Kingfisher Build Ltd., Jordan Kwan, Estate of Debra Elaine Lue by Suzanne Patricia Chen Estate Trustee, 2733214 Ontario Inc., Suhrob Badirov, Lindsay Labow, Tina Larsen, Adrian Lee, June Liddell, Maison de la France, Morogel Maroge, Shawn Melo, Denna Mezuman, Michael Shean, 2044819 Ontario Ltd., Mousi Brothers Inc., Caihan Li, Neurose Corporation North American Gateway, Northwest Precision Ltd., Ornella Parker, Dwight Pollonais, Proteck Roofing & Sheet Metal Inc., Laura Pryse, Shamin Rahim, Mario Rapino, Edward Roberts, Robros Investments Inc., Loudaniel Holdings Inc., 2036133 Ontario Ltd., 2505619 Ontario Inc., Patric Sacdalan, Maziar Sahraei, Manoj Sharma, Signum Wireless Corp., SDM Construction Inc., Davide Succurro, Giovanna Succurro, Kaitlyn Swarta, Tabangi Electronics Ltd., Francesco Tarantino, 2751304 Ontario Corporation o/a Tire Studio, Jonathan To, Crystal Lee, Trifield Construction Management Corp., Krystyn Turco, Kayla Turco, Kurtis Van Keulen, Shannon Wainman, Karen Washington, William Wernicke, Lawrence Weisbrod, Alan Weisbrod, Calvin White, Lorna White, Colin White, Edward Wong, Elizabeth Zalan, Cyrus Orden, Olga Zalan and Sanjay Dubey

CV-23-00700570-0000

Superior Court of Justice – Ontario

Re: Martin Z. Rosenbaum and Martin Z. Rosenbaum Law Professional Corporation, Plaintiffs (Moving Parties)

And: Rosenbaum & Ibe LLP., Vanessa Ibe In her Personal Capacity and as Managing Partner of Rosenbaum & Ibe LLP, Mekker Construction Ltd., Annie Yilmaz, Aykut Yilmaz, Gabriella Moscatello, Evan Braun, Robin Dussart, John Barroso, June Liddell, Lise Varette, Stiffra Armamento, Recipient 1, Recipient 2, Recipient 3, Recipient 4, Recipient 5, Recipients 6-15, David Guy, Blair Laursen, SDM Construction Inc., Client 1, Client 2, Client 3 and Clients 4 to 160

Footnotes

[1] The full titles of proceeding are attached as Appendix A.

[2] There is a sixth action Mr. Rosenbaum refers to as a recovery or protective action. In court file CV-23-0710639-0000, the plaintiffs have brought an action that names only Ms. Ibe, the Firm, and Ms. Ibe's spouse. I do not view that action as similar to the other five "protective actions". It is not considered in or affected by this endorsement.