Ontario · Receivership (court-appointed)
Affidavit of Vipen Chauser sworn October 22, 2025
Affidavit · 22 October 2025
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 filing14 verified
- secured creditorsnote: Approximate figure rounded to nearest $1,000; did not provide requested supporting documentation for this lien claim · page: 9 · as of: 2024-12-16 · amount: 379000 · debtor: 2616766 Ontario Limited · creditor: Classic Fire & Life Safety Inc. · currency: CAD · security: Construction lien registered against the Real Property, registration CE1211115 (per Key Facts Table)
- secured creditorsnote: Approximate figure rounded to nearest $1,000; did not provide requested supporting documentation for this lien claim · page: 9 · as of: 2024-11-29 · amount: 3694000 · debtor: 2616766 Ontario Limited · creditor: Boulder Group Inc. · currency: CAD · security: Construction lien registered against the Real Property, registration CE1208900 (per Key Facts Table)
- secured creditorsnote: Respondent states there is insufficient documentation to substantiate this lien claim; did not provide requested supporting documentation · page: 10 · as of: 2024-07-04 · amount: 1671477.7 · debtor: 2616766 Ontario Limited · creditor: Industrial Floor Systems Corp. · currency: CAD · security: Construction lien registered against the Real Property, registration CE1188154 (per Key Facts Table)
- secured creditorsnote: Claimed remaining balance under a contract with initial price $1,125,000 plus HST, alleged increased to $1,719,995 plus HST (approval unclear); also owes funds to Noble Corporation, creating a possible double-lien claim; Respondent states no funds are directly owed to Ultimate Fire by the Debtor · page: 10 · as of: 2024-11-07 · amount: 540987.97 · debtor: 2616766 Ontario Limited · creditor: Ultimate Fire Protection Limited · currency: CAD · security: Construction lien registered against the Real Property, registration CE1205812 (per Key Facts Table); underlying Statement of Claim issued December 9, 2024 (Court File No. CV-24-00034266-0000)
- secured creditorsnote: Total claim per Receiver's Second Report as at October 1, 2025, comprising First Advance $9,175,000, Second Advance $1,000,000, Promissory Note $125,000, Third Advance $734,271, accrued interest, $250,000 forbearance fees and $442,692.35 legal costs. Amount is disputed by the Respondent/Chauser, who alleges his signatures on several underlying loan documents were forged (forensic report dated Sept 14, 2025) · page: 28 · as of: 2025-10-01 · amount: 16300282.93 · debtor: 2616766 Ontario Limited · creditor: Cerruti Investments Inc. · currency: CAD · security: Mortgage ("Plant Mortgage") registered against the Real Property at 6500 Cantelon Drive, Windsor, Ontario, registration CE996631 (March 16, 2021); a separate priority-analysis Key Facts Table lists a registered mortgage amount of $22,000,000 for this instrument
- secured creditorsnote: Per Endorsement of Justice Dietrich dated September 22, 2025, CII's mortgage debt is subordinate to this creditor's secured claim of approximately $17 million · page: 32 · as of: 2025-09-22 · amount: 17000000 · debtor: 2616766 Ontario Limited · creditor: 2763161 Ontario Limited · currency: CAD · security: Mortgages registered against the Real Property: CE1134394 – initial advance $13,000,000 registered May 16, 2023, and further advance $4,000,000 registered September 7, 2023
- secured creditorsnote: Approximate aggregate figure per Endorsement of Justice Dietrich dated September 22, 2025 ("Construction liens of approximately $11 million are also registered on title"); distinct from the itemized individual lien claims documented elsewhere in the record · page: 32 · as of: 2025-09-22 · amount: 11000000 · debtor: 2616766 Ontario Limited · creditor: Construction lien claimants (aggregate) · currency: CAD · security: Construction liens registered on title to the Real Property
- secured creditorsnote: Claimed for materials supplied to Ultimate Fire Protection Limited on the project; Respondent's position is that Ultimate Fire, not the Debtor, owes this amount, creating a possible double-lien claim; identified as the first preserved lien for priority purposes · page: 74 · as of: 2023-12-28 · amount: 301795.53 · debtor: 2616766 Ontario Limited · creditor: Noble Corporation · currency: CAD · security: Construction lien registered against the Real Property (PIN 01379-0439), registration CE1165316
- secured creditorsnote: Acted as subcontractor to Ultimate Fire Protection Limited; claims priority over mortgages of CII, 2763161 Ontario Limited, Fulger Transport, Tatro Horizons and Joe's Cement Work under s.78 of the Construction Act · page: 181 · as of: 2024-01-03 · amount: 269221.89 · debtor: 2616766 Ontario Limited · creditor: Wallace-Kent Sprinkler Systems Inc. · currency: CAD · security: Construction lien registered against the Real Property (PIN 01379-0439), registration CE1165699; total contract price $813,572.29 including HST
- secured creditorsnote: Approximate figure rounded to nearest $1,000; provided requested supporting documentation · page: 239 · as of: 2025-03-11 · amount: 332000 · debtor: 2616766 Ontario Limited · creditor: Aqua Temp Mechanical Contractors Limited · currency: CAD · security: Construction lien registered against the Real Property, registration CE1220902 ("valid lien" per Key Facts Table)
- secured creditorsnote: Approximate figure rounded to nearest $1,000 per Key Facts Table in a priority-analysis exhibit; character as balance vs. registered principal not otherwise confirmed · page: 239 · as of: 2024-06-08 · amount: 6599000 · debtor: 2616766 Ontario Limited · creditor: Fulger Transport Inc. · currency: CAD · security: Building mortgage (3rd building mortgage) registered against the Real Property, registration CE1184095
- secured creditorsnote: Approximate figure rounded to nearest $1,000 per Key Facts Table in a priority-analysis exhibit · page: 239 · as of: 2025-06-27 · amount: 477000 · debtor: 2616766 Ontario Limited · creditor: Joe's Cement Work (2019) Inc. · currency: CAD · security: Building mortgage (5th building mortgage) registered against the Real Property, registration CE1222890
- secured creditorsnote: Approximate figure rounded to nearest $1,000 per Key Facts Table in a priority-analysis exhibit · page: 239 · as of: 2024-09-11 · amount: 450000 · debtor: 2616766 Ontario Limited · creditor: Tatro Horizons Ltd. · currency: CAD · security: Building mortgage (4th building mortgage) registered against the Real Property, registration CE1197716
- secured creditorsnote: A separate lien filed by 1627149 Ontario Limited (owned by Windsor P&L) for $1,787,933.18 appears to be a duplicate of this claim; supporting documentation (underlying contract, approved Purchase Order) is incomplete. A prior registration CE1198185 dated September 13, 2024 for $1,787,933.18 is characterized as an "invalid lien (to be vacated)" and should not be treated as current · page: 239 · as of: 2024-12-12 · amount: 2013933 · debtor: 2616766 Ontario Limited · creditor: Windsor Power & Light Ltd. · currency: CAD · security: Construction lien registered against the Real Property, registration CE1210575 ("valid lien" per Key Facts Table), perfected by Certificate of Action registered January 16, 2025 (CE1214462)