Ontario · Receivership (court-appointed)
Reply Motion Record of the Receiver (Supplement to Fifth Report) 27-OCT-2026
Application / notice of application · 27 October 2026
AI summary
A plain-English summary drawn only from this filing: what it is, why it matters, and the parties, amounts and dates it turns on.
What we verified from this filing6 verified
- unsecured creditorsnote: Disputed; alleged total claim, not an adjudicated debt, and largely directed at Wekerle/Wekerloo/Waygar rather than a stated debt of the Debtors. Components: $2,486,000; $565,000; $905,000; $1,186,500; $1,480,000; $888,000. Receiver characterizes the Arbour Parties' position as tactical. · page: 26 · basis: Plaintiffs' stated total claim including HST in the Amended Statement of Claim (Court File CV-25-00739407-00CL); includes the WIN2 mortgage-inflation, share sale, Wekerle debt, Ford leasehold, participation agreement deficiency and Wekerle salary components · amount: 7510500 · creditor: Mark Arbour and Waterloo Innovation Network PM Inc. (claims against Wekerle, Wekerloo, Waygar and others) · currency: CAD
- unsecured creditorsnote: Disputed claim, unadjudicated. $1,050,000 plus HST for leasehold improvements for Ford Canada performed in 2018 (the same pleading elsewhere states $1,186,500 with HST, an internal inconsistency). Not an adjudicated debt. · page: 27 · basis: Allegation in Arbour Parties' Amended Statement of Claim (issued May 22, 2025); WIN PM commenced an action against WIN2 in 2022 · amount: 1365000 · debtor: Waterloo Innovation Network 2 Inc. · creditor: Waterloo Innovation Network PM Inc. (Ford leasehold improvements) · currency: CAD
- unsecured creditorsnote: Disputed litigation claim; no amount claimed against WIN2 stated; $900,000 is the alleged personal investment by Camacho, not a claim against the Debtors. Columbia Data Vault is also a tenant at 176 Columbia Street West. · page: 29 · basis: Action commenced Dec 6, 2024 against Wekerle and others (WIN2 named as a defendant per APS excluded-assets list, Court File CV-24-00002087); Camacho alleges investing $900,000 of personal funds · debtor: Waterloo Innovation Network 2 Inc. · creditor: Gerald Camacho / Columbia Data Vault Inc. · currency: CAD
- secured creditorsnote: Listed in the security opinion as a Lender; secured against litigation proceeds. No amount stated on these pages. Arbour Parties allege Wags obtained priority over a portion of Waygar's security (Waygar postponed PPSA registration to Wags) and that the funding agreement is champertous/illegal (allegations only). · page: 36 · debtor: Waterloo Innovation Network 2 Inc. and Waterloo Innovation Network 3 Inc. · creditor: Wags Investments Incorporated · currency: CAD · security: Litigation Funding Agreement dated Nov 3, 2022 (amended July 2024), Irrevocable Direction to Stewart McKelvey, and Assignment of Litigation Proceeds, all dated Nov 3, 2022
- secured creditorsnote: Dollar figures are registered principal amounts (registration ceilings), not outstanding balances; no outstanding balance stated on these pages. The Arbour Parties' claim alleges the $30M is inflated by $22M (disputed, allegation only). The Commitment letter was amended six times (to Aug 20, 2024) per the security opinion. Security opinion's validity/priority conclusions are not on the pages provided. · page: 36 · debtor: Waterloo Innovation Network 2 Inc. and Waterloo Innovation Network 3 Inc. · creditor: Waygar Capital Inc., as agent for Ninepoint Canadian Senior Debt Master Fund LP (First Waygar Charge) · currency: CAD · security: Charge/Mortgage on 176 Columbia Street, Waterloo, Instr. WR1137400 (Sept 7, 2018), originally $8,000,000, amended to $11,200,000 (Aug 1, 2019), $13,000,000 (Mar 20, 2020) and $30,000,000 (Apr 13, 2021); Notice of Assignment of Rents WR1137401; General Security Agreements from WIN2 and WIN3 dated Sept 7, 2018
- secured creditorsnote: $15,000,000 is the registered principal / guarantee maximum, not a balance. Arbour Parties allege the March 2023 mortgage was granted without consideration, for the debt of El Mocambo (not WIN2), and is contrary to the Assignments and Preferences Act (disputed, allegations only). · page: 36 · debtor: Waterloo Innovation Network 2 Inc. · creditor: Waygar Capital Inc., as agent for Ninepoint Canadian Senior Debt Master Fund LP (Second Waygar Charge) · currency: CAD · security: Charge/Mortgage on 176 Columbia Street, Instr. WR1515962 registered June 26, 2023, principal amount $15,000,000; Notice of Assignment of Rents WR1515963; Guarantee Agreement by WIN2 in maximum principal $15,000,000