Ontario · Receivership (court-appointed)
Motion Record of the Receiver (Tarion Letter of Credit Dispute)
Application / notice of application · 6 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 filing4 verified
- secured creditorsnote: Amount is Tarion's claimed indemnity from JPLP for deposit warranty claims paid to Freehold Unit purchasers; the Receiver understands this is Tarion's claim (disputed in part). Tarion drew $1,440,000 on the Freehold LOC and $1,846,001.10 on the Condo LOC on or about December 23, 2025; the Receiver disputes the Condo LOC draw as a breach of Vendor Agreement art. 3.8.3 and seeks its return or cash collateral. LOC face values are facility limits, not balances. LOCs were issued at the request of an investor in the first mortgage administered by Cameron Stephens. · page: 10 · as of: 2025-12-23 · amount: 3286001.1 · debtor: Jefferson Properties Limited Partnership · creditor: Tarion Warranty Corporation · currency: CAD · security: Letters of credit issued by Bank of Montreal in favour of Tarion: Condo LOC BMTO8000666OS ($2,400,000 face value) and Freehold LOC BMTO786681OS ($1,440,000 face value); indemnity under Vendor Agreement dated February 2021
- secured creditorsnote: Amount not stated on these pages. Court-ordered priority charge, not a conventional secured creditor. · page: 39 · as of: 2023-12-21 · debtor: 2011836 Ontario Corp.; Jefferson Properties Limited Partnership · creditor: Receiver and counsel (Receiver's Charge) · currency: CAD · security: Court-ordered Receiver's Charge, a first charge on the Property for fees and disbursements, ahead of all security interests, subject to BIA ss. 14.06(7), 81.4(4), 81.6(2)
- secured creditorsnote: The borrowing limit was later increased by court orders: to $11,500,000 (March 4, 2024), then $31,500,000 (May 2024 motion, granted per June 18, 2024 decision), then a request to $40,000,000 (Second Borrowing Limit Motion, April-May 2025, granted). Limits are ceilings, not drawn balances; outstanding amount not stated on these pages. · page: 40 · as of: 2023-12-21 · debtor: 2011836 Ontario Corp.; Jefferson Properties Limited Partnership · creditor: Receiver's Borrowings Charge (holders of Receiver's Certificates) · currency: CAD · security: Fixed and specific charge over the whole of the Property, subordinate only to the Receiver's Charge and BIA charges. Original borrowing limit $7,000,000 (Appointment Order, para. 20)
- secured creditorsnote: Approximate figure ('approximately $58 million') per Kimmel J.'s bankruptcy decision as recited in the Dietrich J. reasons; stated as of October 2025. Lender expected to suffer a shortfall of at least $15 million. Personal guarantee exists from the Debtors' principal (individual named in the reasons). · page: 258 · as of: 2025-10 · amount: 58000000 · debtor: 2011836 Ontario Corp.; Jefferson Properties Limited Partnership · creditor: Cameron Stephens Mortgage Capital Ltd. (senior secured lender; administers first mortgage against the Real Property) · currency: CAD · security: First mortgage against the Real Property (39, 53 and 67 Jefferson Side Road, Richmond Hill); guarantee executed by Fengxi Wang (principal of the Debtors) in favour of the Lender