Toronto Estate Law Blog : Toronto Estate Lawyer : Hull & Hull Law Firm : Trust Mediation and Succession Planning : Serving Ontario, Ottawa, Mississauga, Hamilton

• Email This
• Print
• Comments
• Trackbacks
• Share Link

On August 15, 2011, I blogged on the decision of Hennessy J. in Makarchuk v. Makarchuk, 2011 ONSC 4633 (CanLII).  There, the court found that a separation agreement did not preclude the surviving spouse from benefitting under the deceased’s will.

On Monday this week, the Ontario Court of Appeal dismissed the appeal, and upheld the decision of the lower court.  In a brief endorsement, the Court of Appeal stated “We have not been persuaded that the application judge erred in her interpretation of the Separation Agreement. Since the deceased never revoked his will, the gift in the will to the respondent stands.”

The Court of Appeal also dismissed a motion to admit fresh evidence. No particulars of this motion were given.

As I stated in my prior blog, separated spouses must consider their estate plan, including terms of their wills and beneficiary designations to ensure that their intentions are properly reflected.  In the case of Makarchuk, it is not clear whether the husband intended to benefit his separated spouse.  However, as the lower court noted, had he wished to not do so, there were a number of means available to him to effectively revoke the gift he had made to his spouse prior to their separation.

Have a great weekend.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

A “festival” running at London’s Southbank Centre in January explores death from all angles. The festival will explore attitudes towards death, using music, workshops, literature and art installations. Festival events range from the whimsical to the serious.

Highlights include an art installation entitled “the ‘Boxed’ coffin exhibition”, which features a number of unusual coffins, including coffins in the shape of a dumpster, a lion, a Mercedes, a car, and a skateboard.

Less light-hearted events include a debate on assisted dying; a music concert featuring composers obsessed with death; an art installation that commemorates the 250,000 people that will be born or die in 12 hours around the world; a poetry workshop on writing poetry when dealing with the grief associated with the death of a loved one, and a pseudo-funeral procession borrowing from a New Orleans funeral parade.

Other events include a chalkboard where attendees can record an item from their “bucket-list” of the one thing that they want to do before they die, and a children’s play chronicling the last days of a pet guinea pig.

Together, the festival’s numerous events shed light on and led to healthy discussion of a topic many are reluctant to talk about. 

Thank you for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Renowned blues singer Etta James died last week at the age of 73. She succumbed to chronic leukemia, complicated by dementia and kidney problems.

Etta James had a particular significance to me. After buying my first CD player, Etta James’ CD was the first CD that I purchased. That CD got a lot of play.

Etta James lived a turbulent life. She was born to a mother whom Etta described as a scam artist, a substance abuser and a fleeting presence during her younger years. She did not know her father. During her lifetime, she would battle addictions.

However, as a musician, she soared. She was inducted into the Rock and Roll Hall of Fame, and won numerous Grammys, including a special lifetime achievement Grammy in 2003.

Near the end of her life, her health declined, and here family was involved in a dispute over her care. Her two sons had challenged decisions being made by Etta’s husband, who was the conservator of Etta’s $1m estate.  The dispute was reported as settled, with the husband staying on as conservator, and the amount available for her expenses and care being fixed at $350,000. The sons were also to receive a full financial accounting of Etta’s music catalogue.

Thank you for reading.

Paul Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

In a recent Québec decision, Ms. Rodrigues, the young widow of the late boxing champion, Arturo Gatti, has succeeded in her battle over her late husband’s estate.  

We previously blogged on this case in 2009 and 2010, as it wound its way through the court system. At issue was the validity of two Wills.  The more recent Will left the entire estate to the widow, which Will she was seeking to have declared valid. 

Mr. Gatti’s family contended, however, that an earlier Will was the valid last Will, which left the bulk of the estate to Mr. Gatti’s mother.  Importantly, the signed prior Will was never located. 

The Court found that the last Will was valid, and that Ms. Rodrigues did not manipulate Mr. Gatti into signing it.

The decision does not end the legal troubles for the estate and the family, since it is reported that there is a court date coming up in New Jersey to deal with a wrongful-death suit by Mr. Gatti’s former girlfriend Erika Rivera, the mother of his daughter, Sofia, and there is a trial pending in Florida involving a man suing Mr. Gatti for injuries he allegedly received from the late boxer.

Thanks for reading,

Natalia R. Angelini - Click here for more information on Natalia Angelini. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

In Re Brooks Estate, 2011 BCSC 1606 (CanLII), a testator left a handwritten will in which he left his real property and two bank accounts to his “brother … Executor with Power of Attorney”. He goes on to list five other people and states “I would all the people named above to share equally in my estate [sic].”

The Estate Trustee applied for directions on the interpretation of the Will. Did the real property and accounts pass to the brother, or where they to be divided equally amongst the brother and the five other named beneficiaries?

Important to the decision was the fact that the real property and accounts made up the bulk of the estate.

What did the court do? The court found that the estate was to be divided amongst the five named beneficiaries and the Estate Trustee. The court noted that extrinsic evidence could be used to interpret the Will if there was ambiguity, and held that the only extrinsic evidence of relevance was the fact that there were no significant assets other than the real property and the accounts. The testator, the court held, must be presumed to know what his estate consisted of, and that there would be no significant residue beyond the specified assets. 

In any event, the court held that extrinsic evidence was not required, as there was no ambiguity. The testator referred to “my estate”. “In the absence of any further language limiting their application, the plain and ordinary meaning of those words is that all individuals named in the will share equally in the entire estate.”

Costs of all parties were ordered to be paid from the estate. The modest estate had a value of approximately $275,000. Presumably, the costs of the parties absorbed a significant part of the estate: costs which could have been avoided by a properly drafted will. Perhaps a better title for this blog would be “The Perils of a Handwritten Will.”

Thank you for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

The onus of proving undue influence is on the challenger. By its nature, undue influence is often very hard to prove. However, the court may resort to a presumption of undue influence in certain circumstances.

In a thought-provoking article in the December 2011 issue of The Lawyers Weekly, Adam Parachin, an associate professor at the Faculty of Law, University of Western Ontario, discusses the high onus to be met in undue influence cases, the application of a presumption of undue influence in certain cases, and the perils of strengthening the presumption of undue influence.

Specifically, Parachin states that the court’s increasing willingness to accept circumstantial evidence of undue influence possibly means that the need for a presumption is less obvious. Further, identifying “triggers” to the imposition of a presumption leads to a circular argument: “instances best meeting this requirement [to trigger the presumption] are those where the need for the presumption is the least apparent.”

Further, the application of the presumption may detract from the testamentary freedom of the testator. As noted by Parachin, the application of the presumption could disproportionately jeopardize wills that depart from the usual pattern of estate distribution, or wills that are not prepared in accordance with the usual protocols. In addition, testamentary freedom should extend not only to how one’s estate is to be distributed, but to who is to be included in the will making process. 

Finally, Parachin states that a strong presumption might facilitate questionable claims. The costs of defending these claims, and of rebutting the presumption, would bolster these questionable claims, and lead to compromises that might, in many cases, be contrary to the testator’s intention.

Let the debate begin.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

In an intriguing case out of the Prince Edward Island Court of Appeal, the question of whether a wife could claim damages for economic loss and loss of care and companionship against her husband’s estate arising from the husband’ own negligence which lead to his death was considered.

In Hubley v. Hubley Estate, 2011 PECA 19 (CanLII), the husband died in a car accident that was a result of the husband’s negligence. The wife claimed that as a result of her husband’s death, she lost the benefit of her husband’s earnings, and his retirement pension benefits. She also claimed the loss his care, guidance and companionship.

Those claims were dismissed on motion, and the wife appealed to the Court of Appeal.

On appeal, the Court of Appeal agreed with the motions judge. 

The Court of Appeal framed the issue as being whether the husband owed the wife a prima facie duty of care to protect himself from injury and/or death. 

The Court of Appeal noted that the court will proceed with caution in allowing for recovery of economic loss when the plaintiff has not suffered physical harm or property damage. (The fact that the wife was injured in the car accident was not seen as being the physical harm necessary to support a duty of care: her claim for damages related to her husband’s death, and not her injuries.)

The Court of Appeal noted that finding a duty of care in the circumstances would have far-reaching policy consequences. There could be indeterminate liability. Finding a duty of care not to harm oneself would also lead to “complex and unsettled questions as to how people lead their lives. … There could be a whole range of situations giving rise to law suits ranging from one’s failure to wear a seatbelt to risking one’s own health by lifestyle choices.” Finding a duty of care not to harm oneself “would impact on one’s right to self-determination and freedom of choice.”

Thanks for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

I saw “The Descendants” on the weekend. It is a great movie in its own right, but also a great movie from the perspective of an estates and trusts lawyer. The movie raises a number of estates and trusts issues: trusteeship, powers of attorney, living wills, and the threat of estate litigation.

Without wanting to give away the plot, one of the issues referred to in the movie is the “rule against perpetuities”. I don’t expect that “rule against perpetuities” movies will be a new film genre. However, it is an interesting concept and significantly moves the story in “The Descendants” forward.

Simply put, and as well explained in the movie, the rule provides that no interest in a trust will be valid if the trust vests more than twenty-one years after the termination of some life in being at the time of the creation of the trust. The effect of the rule is that a trust cannot continue on indefinitely, and must vest at some point: that is, the trust must vest twenty-one years after the death of a prescribed person. 

Much case law, legislation and commentary has evolved in relation to the rule against perpetuities. However, the general application of the rule in most cases remains, and property in a trust cannot be held in the  trust indefinitely.  We cannot freeze the past forever, and must move on.

Thank you for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle

• Email This
• Print
• Comments
• Trackbacks
• Share Link

A helpful article in the Toronto Law Journal (November 2011) speaks to the new Rules on time limits for examinations for discovery, specifically Rule 31.05.1(1), which provides that "no party shall, in conducting oral examinations for discovery, exceed a total of seven hours of examination, regardless of the number of parties or other persons to be examined, except with consent of the parties or with leave of the court".

In J.P. Leveque Bros. v. Ontario, a motion for leave to exceed the seven hour time limit was before the court. The motion was granted.

The motion judge stated that the court must consider the factors set out in Rule 31.05.1(2), including effective representation, cost efficiency and expediency.

This decision is instructive in that the court interpreted the limit of seven hours to mean seven hours of "actual discovery" on the record, such that it does not include breaks, adjournments, a party's bad conduct or unreasonable interference that results in unduly shortening examination time.

The court also stated that: "...in circumstances in which the time limit agreed upon in the Discovery Plan has expired and counsel is at a crucial point in his/her examination on an issue central or germane to the case, flexibility ought to be brought to bear and that further time to a maximum of one hour to continue and conclude the examination would not be unreasonable in the circumstances".  Further, where there are multiple parties this additional one hour should be recovered by being deducted from the examination of another party.

Have a good day,

Natalia R. Angelini - Click here for more information on Natalia Angelini. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

The opportunity of obtaining leave to appeal to the Supreme Court of Canada does not come around too often in our area of practice. While daunting, it is a challenge I would love to meet. That is why I was captivated by an article in the National (Volume 20, No 7) addressing what we need to know before seeking leave.

 The key points I noted are:

·                    Different test - it is not good enough to file the factum relied on before the Court of Appeal; you are addressing a different test - the public importance or national interest test.

·                    Reframe the Case as a Public Importance Issue – this is critical - Supreme Court Rules were recently amended to require applicants to highlight the public importance of the case at the outset of the written materials. While we are encouraged to lift our sights and put the judgment in a broader context, the difficulty may be that “public importance” has not been defined.  That said, some guidelines do exist, such as the issue of public importance must be central to the case and not moot or about to be dealt with by legislation.

·                   Pause – you may want to reflect for a week or two, then write a couple of pages about why the issue is one of public importance (not why the Court of Appeal erred) and have a colleague review it.

While the main theme here is public importance, given that only about 10% of leave applications are successful, and this test seems to be the gatekeeper, it is a point worth stressing.

Have a good day,

Natalia R. Angelini - Click here for more information on Natalia Angelini

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Given the rapid developments in technology, it is only a matter of time before the days of a paper-reliant law practice will be a thing of the past. Our office is doing its part by going paperless and, although a major change, it is one that we have embraced. 

That said, we still use paper for certain aspects of our work, including to file materials with the courts. An article in the September issue (Vol 20, No. 6) of the Canadian Bar Association’s National addresses the fact that while e-discovery and technology has changed the way we litigate, the courts in Canada are lagging behind. 

E-trials continue to be rare in Canada (in contrast to the US). The Honourable Mr. Justice Gans has reportedly commented on the issue, suggesting that reticence from some judges to use a document management system in a trial and the fact that the (Ontario) Ministry of the Attorney General has yet to get behind the initiative, means that pressure to move the courts towards more e-trials needs to come from the lawyers. 

The author advocates the benefits of having this available to us in the courtrooms, including saving trial time and assisting in making clearer arguments as it will likely be easier to knit all of the documents, videos and images of evidence together.   

Enjoy the weekend,

Natalia R. Angelini - Click here for more information on Natalia Angelini. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Friends do things for each other. Some more than others. At what point does the help and assistance given by one friend to another give rise to a claim for unjust enrichment? This was the issue considered in the recent British Columbia decision of Brennan v. Gardy Estate, 2011 BCSC 1337.

As stated by the Honourable Madam Justice Fenlon, the main issue in the case was whether one friend's contributions "were of a kind and magnitude to establish unjust enrichment or were simply part of the mutual enrichment inherent in a close friendship."

Fenlon J. began her ruling by setting out the test to be met in order to establish unjust enrichment. This requires that the claimant establish:

            i.          An enrichment or benefit to the deceased;

            ii.          a corresponding deprivation to the claimant; and

            iii.         the absence of a juristic reason for the enrichment.

Fenlon J. undertook a careful assessment of the evidence with respect to each of these three criteria. She assessed the nature of the friendship and the services provided. She found that there was a benefit to the deceased from the services rendered; and because the claimant was not paid for his services rendered, there was a corresponding deprivation to the claimant.

However, the claimant was not able to succeed on the third criteria. The court cited case law to the effect that at this stage of the analysis, the courts can look at all of the “circumstances of the transaction” in order to determine whether there is any other reason to deny recovery. 

The Court observed that the claimant lived with the deceased and paid less than market rent while he lived there. Rather than a contract for services in exchange for rent, the court found that the claimant provided the services he did with a "donative" intent. In fact, the claimant acknowledged that he did not expect to be compensated for the services he provided to the deceased. Nor did he expect to receive any benefit from the deceased’s estate after his death. One witness described the relationship between the claimant and the deceased as one of "mutual caretaking". The Court noted that the claimant and the deceased gave to each other freely and generously. "In short, this was a case of mutual giving arising out of a close mutual friendship." This mutual giving was a relevant consideration in determining their reasonable expectations and the existence of a juristic reason for the conferral of the benefit in issue. 

In any event, Fenlon J. stated that even if there was no juristic reason for the conferral of the benefit, she would not have the remedy stage award damages to the claimant because of the benefits he received in return from the deceased which equalled or exceeded those he provided to the deceased.

Thank you for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

When is a gift not a gift? When it is not accepted.

The issue of gifting and acceptance was considered recently in Leclair v. Canada, 2011 TCC 323.

There, a father gifted real property to his daughter. He did so, however, at a time when he was indebted to CRA. CRA assessed the daughter as being liable for the father’s unpaid taxes pursuant to s. 160 of the Income Tax Act. S. 160 renders a recipient of a transfer of property liable for the donor’s unpaid taxes if the recipient was a spouse, under 18 or a person with whom the donor was not dealing at arm’s length.

The court found that the daughter did not have knowledge of the transfer. Upon learning of it, and the father’s liability, she retransferred the property back to her father. 

The court considered a number of cases dealing with acceptance of or disclaimer of a gift, and case law to the effect that a failed testamentary gift is not caught by s. 160. It went on to hold that the same rules applied to inter-vivos transfers. A transfer of an inter-vivos gift must be a completed transfer, and not a failed or void transfer, and further, that intent and delivery by one party alone is insufficient to complete a gift. The gift in question was not accepted, and once the daughter had knowledge of it, it was repudiated within an acceptable time. The transfer back by the daughter amounted to a valid disclaimer of the gift, and she was found to not be jointly liable for her father’s tax debt.

Until tomorrow,

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Non-traditional families face particular challenges when dealing with estate planning. Some legislation does not fully apply to non-traditional marriage. For example, a spouse’s right to elect to take an equalization of Net Family Property upon the death of a spouse under Ontario’s Family Law Act, only applies to married spouses.

“The Gay Estate: Non-Traditional Families and the Law”, a blog maintained by Chris Tymchuck, a lawyer in Edina, Minnesota, provides helpful information for unmarried, gay, separated, divorced adoptive or “other unique families”: families who fall outside of the so-called “traditional” family structure (or as Chris says, “most of us”).

The informative site focuses mainly on the laws governing estate planning. However, it sometimes verges into other related areas. The well-laid out blog is organized by categories, making for easy access to information. The blog is well written, and the absence of legalese makes it easy for non-lawyers to understand.

Recent topics include the use of life insurance to provide for loved ones, and a two-part series on documents that should be in place in the event of death.

A very worth-while read.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

“No religion prohibits organ donation.”

This is according to an article posted on the Toronto Star’s “Health Zone”. The article by Barbara Turnbull entitled “Religious leaders confront myths that stop faithful from donating organs” notes that in the GTA, just 12% of the population has registered as organ donors.  This may be a factor of the GTA’s rich diversity of culture.

The prevailing belief among many religious groups is that preservation of the integrity of the body is required upon death. However, no religion prohibits organ donation, and many religious leaders from various faiths are working to change the prevailing public opinion.

The article quotes Jewish, Muslim and Hindu religious leaders: all of whom support organ donation. However, they note that much work must be done in order to overcome prevailing attitudes. “We have to change it so that it’s not only okay to do it, it’s not okay not to do it”, says Rabbi Reuven Bulka.

The article reports that 1,547 people are awaiting organ transplants in Ontario, and every three days, someone dies while waiting for a transplant. Hopefully, these numbers will change for the better.

Have a great Thanksgiving weekend. And please sign your organ donation card.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

The Honourable Justice I. Laskin provided some suggestions on factum-writing in his paper Forget the Wind Up and Make the Pitch: Some Suggestions for Writing More Persuasive Factums.  While I can't get into the detail I would have liked to in this blog, I have selected a few points that resonate with me.  They are:

- Put yourself in the position of the judge who knows nothing about the matter - identify and frame the key issue and think about the story you will tell around it so as to reach the best conclusion;

- Write an overview statement (one page maximum) that tells the court what the case is about, the issues and your position on them - the overview is important and gives judges the road map for the rest of your factum;

- State your point before you develop or discuss it;

- Ensure the pages have enough white space, as it improves the visual impact;

- Story-telling is persuasive - first tell the court why you should win (how you present the facts) and then how to get there (how you present the law);

- Candour is essential - be fair to the record, don't overstate your claims, face up to your weaknesses and don't denigrate your opponent's case;

- Avoid using "it is respectfully submitted" more than twice, avoid false intensifiers, avoid the word "not" and avoid excessive us of the passive voice; and

- Last but not least - be concise.

Thanks for reading,

Natalia R. Angelini - Click here for more information on Natalia Angelini. 
 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Yesterday, I blogged on the September 14, 2011 LSUC CLE program entitled “Practice Gems: The Administration of Estates 2011: Avoiding the Pitfalls. This excellent program featured a number of great speakers. The program is being repeated on October 31, 2011, and I highly recommend it.

Another speaker was our own Craig Vander Zee. Craig spoke on the topic of administering an estate where there are claims made against the estate, such as claims for equalization under the Family Law Act, dependant support claims under Part V of the Succession Law Reform Act, or trust claims, such as claims involving jointly held assets, or quantum meruit claims.

Such claims necessarily complicate the administration, and give rise to a number of issues and considerations on the part of the Estate Trustee. Craig’s paper addresses a number of these issues, including the nature of the claim, what procedural steps must be taken to defend the claim, representation and notice to all of the interested parties, limitation periods, and the thorny issue of costs.

Thank you for reading, and have a great weekend.

Paul E. Trudelle - Click here fore more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Yesterday, I attended at a seminar put on by the Law Society of Upper Canada entitled “Practice Gems: The Administration of Estates 2011: Avoiding the Pitfalls”. (There is a repeat performance scheduled for October 31, 2011: see details here.)

One of the presenters was Clare Burns. She has prepared an excellent checklist for solicitors advising estate trustees. The checklist covers topics such as the first interview with the client, reviewing wills, codicils and affidavits of execution, preparing and delivering initial report to the client, determining the estate assets and liabilities, applying for the Certificate of Appointment, realizing and distributing the estate, and preparing the final report to the client. Under each heading, there are detailed descriptions of matters to be considered.

Ms. Burns has advised that she hopes to have the checklist available on the LSUC website shortly.

Solicitors are encouraged to download the checklist, and personalize it and expand to it according to their needs and experience.

The benefits of using a good checklist cannot be overstated. They are an essential tool in any practice.

Thank you for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

A recent article by Ted Rechtshafen in the Globe online edition encourages us to think about our retirement prospects, and plan for them.

The author notes that in 1921, the average life expectancy for a Canadian male was 58.8 years, while the mandatory retirement age was usually 65. At that time, financial planning for retirement was not an issue for most.

Good news: life expectancies have gone way up. Bad news: we now need to plan for a (hopefully) much longer retirement. Most Canadians should plan for, conservatively, a 30-year retirement!

Planning for retirement means considering the following basic questions:

-Do I need to think about ways to work beyond age 60-65?

-Am I saving enough for retirement?

-What is my world going to look like in 25 years?

The article contains links to tools such as a detailed “How long will I live” calculator. The calculator is eye-opening and instructive, and worth a visit. Other links include a “How much money will I have at the end” calculator, which estimates the value of your estate, assuming you live to a full life expectancy. Again, eye-opening.

Thanks for reading.

Paul E. Trudelle - Click here for more information on Paul Trudelle. 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Cremation Solutions has come up with “a new and exciting way to memorialize your loved one.”

The company offers a number of cremation urns and other mementos. One of their most notable products is the “Personal Cremation Urn”. The company offers to create a custom cremation urn in the image of your loved one, favourite celebrity, hero, or even President Obama.

The urns are made from a tough polymere compound, and come on a solid marble base. The company will create the urn using a photograph or two of the subject. 

Cremation Solutions says that the urns can have hair added digitally for short haired people, or, for longer haired subjects, a wig can be added.

The urns come in two sizes: full size, 11” tall (to hold the ashes of an adult) or keepsake sized, 6” tall, to hold a portion of the cremated ashes. Full size is $2,600 US, and keepsake sized is $600 US. Delivery is free.

Thank you to Gerry Beyer and his blog Wills, Trusts and Estates Prof Blog for the reference.

Have a great week.

Paul E. Trudelle - Click here for more information on Paul Trudelle.