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Preparing to Transition Under the New Societies Act (B.C)

Written by Krystin Kempton, Associate.

The new Societies Act comes into force on November 28, 2016. All societies in British Columbia will have two years to transition under the Societies Act or face dissolution. To transition, a society must submit a transition application, which contains the society’s updated constitution and bylaws (as prescribed by the Societies Act and described below) along with a statement of its directors and registered offices. The Society will need to consider whether to identify itself as a “member funded” society, as discussed below. The transition application is submitted online through the BC Registry Services website.

Constitution and Bylaws under the new Societies Act

The content of a society’s constitution will be limited under the Societies Act. Each society will need to prepare a version of its constitution that consists of nothing but the society’s existing name and purposes, word for word as it appears in the society’s constitution on file with the Corporate Registry. Any provisions of the existing constitution other than the society’s name and purposes must be relocated to the society’s bylaws.

The society will need to prepare a complete set of its existing bylaws in consolidated form, including any amendments to the original bylaws that have been filed with the Corporate Registry. The provisions of the constitution, other than the society’s name and purpose, must also be added to the bylaws, without alteration. Any provisions from the constitution currently identified “unalterable” for a society must now be identified as “previously unalterable”.

Alternatively, a society may wish to prepare a new set of bylaws – either adopting the standard form of bylaws under the Societies Act or tailoring the standard bylaws to fit the needs of the society. Preparing to transition is a good opportunity to clarify or refine provisions. However, if the society adopts new bylaws on transition, it cannot change or delete any of the “unalterable provisions” that were in its constitution. Those must be added in, without alteration, to the new bylaws and identified as having been “previously unalterable”. Once the society has transitioned, it can then alter previously unalterable provisions by complying with the Societies Act bylaw amendment procedures.

Procedure for Transitioning

A society does not need to have a general meeting and a vote in order to reorganize its constitution and bylaws if it is simply moving provisions from the constitution to its bylaws, marking certain provisions as having been previously unalterable, and consolidating its bylaws.

If the society adopts new bylaws or amends its bylaws (other than adding the provisions shifted from its constitution and marking them as previously unalterable, or consolidating its bylaws), the members of the society must approve the bylaws or the bylaw amendments by a special resolution. What constitutes a special resolution will vary depending on the society’s bylaws.

In the transition application, the society will be asked whether it wishes to designate itself as a “member funded society” by including a statement to that effect in its constitution. A member funded society is funded primarily by its members to carry on activities for the benefit of its members (i.e., sports clubs, golf courses and professional associations). Member funded societies have modified standards applicable to them under the Societies Act. The members of the society need to authorize this designation by a special resolution.

Finally, the directors and registered office information must be updated. The society must also be up to date with annual reporting in order to transition.

There is no filing fee payable to transition under the Societies Act.

November 14, 2016

Your Local Legal Experts

In the Community, Blog

When you need the services of a lawyer, what motivates you to choose a specific law firm?
At Nixon Wenger we have been committed to providing exceptional legal service to the North Okanagan and beyond. We pride ourselves on being a law firm that can assist with the everyday issues of the people in our community, from preparing wills and conveyancing real estate to advising multi-national corporations with complex transactions or litigation.

Watch our recent promo video below and see how Nixon Wenger can be your firm.

We are your local legal experts.
Choose local, choose experience, choose Nixon Wenger.

November 8, 2016

Glover v. Leakey: Mistrial, ICBC Abuse of Process

Personal Injury, Blog

Written by Mike Yawney, Partner.

Senior Litigation partner Michael Yawney and associate Ryan Irving recently obtained an interesting decision in a case called Glover v. Leakey. In that case, the Defendant was involved in a crash and injured two passengers. One sued and fault was specifically admitted; only quantum was then in issue and that issue was settlement. The second passenger was our client, Ms. Glover, she also sued, but fault for the accident was specifically denied. Both claims were defended by ICBC.
In the midst of a two week jury trial Mr. Yawney and Mr. Irving discovered the inconsistent pleadings and brought an application claiming that this was unfair and amounted to an abuse of process, asking for a directed judgment on liability. The application was heard and the decision on abuse of process deferred, by agreement with counsel and the judge. This apparently was misunderstood by defence counsel. Due to the apparent misunderstanding the matter proceeded to verdict on liability and the jury found the Defendant was not negligent. Before the order was entered the Court considered the matter and found that the liability denial was an abuse of process, set aside the jury verdict and granted judgment on liability in favour of the plaintiff. In reaching this result Madam Justice Gropper provided the following reasons:

[67] In considering my analysis of this application, I must note that the Insurance Corporation of British Columbia (ICBC), the Province’s public mandatory motor vehicle insurer had conduct of both the Glover and the Yeomans actions. The evidence provided is sparse, but it is clear that the adjuster in the Yeomans Action determined that liability would be admitted on behalf of Mr. Leakey whereas the adjuster in the Glover action determined that liability would be denied. I expressly find that ICBC knew of the inconsistent pleadings and that the insured, Kenneth Leakey knew or ought to have known of the inconsistent positions.

[68] Courts retain jurisdiction to dismiss actions that are an abuse of process where the principles such as judicial economy, consistency, finality and the integrity of the administration of justice will be violated. This doctrine is flexible and the categories of abuse of process are open. In my view, the defendant’s inconsistent positions on liability offend all these principles which are fundamental to our system of law.

[69] Before this action was filed the defendant admitted liability for the subject accident in the Yeomans Action. He obtained the benefit of settlement with that defendant. It cannot be open to him to re-litigate something that he already conceded in the Yeomans Action. That offends the principle of judicial economy, unnecessarily expending the resources of the justice system and in this particular instance it is more egregious as the case called upon the wisdom of the community in the form of jurors. It is also contrary to the principle of finality to permit something that has been admitted to be re-litigated.

[70] Consistency is also compromised. A position that Mr. Leakey is on one hand negligent but on the other not negligent cannot be anything but irreconcilable and inconsistent. The only distinction in the pleadings is that in the Yeomans Action the defendant asserted that Ms. Yeomans failed to properly adjust and securely fasten her seatbelt. That does not alter the bare fact of the defendant’s negligence.

[93] The defendant claims that to find these pleadings as inconsistent and an abuse of process will discourage admissions, contrary to public policy. I find that there is much larger public policy at stake. It is an abuse of process to allow a defendant to admit liability in respect of one passenger and deny liability in respect of the other where there are no facts to distinguish the two. Requiring a party, even ICBC, to file consistent pleadings is not onerous and, with respect, is a principled way to proceed. The pleading of inconsistent positions in this case cannot be condoned.

[94] I have declared a mistrial in this case. It may appear that my decision on the abuse of process application is moot. It is not for three reasons:

1. A declaration of mistrial means that the matter will proceed to a new trial.
2. I grant judgment on the liability issue in favour of the plaintiff.
3. The plaintiff seeks special costs related to the abuse of process and has asked for leave to provide further submissions in that regard.

[95] Both parties may seek to appear to address the issue of special costs based on my finding of an abuse of process.

This decision is an important one in terms of ensuring more fairness to injured Plaintiffs bringing claims. It is also important in terms of the cost of this type of litigation; putting more onus on insurance companies like ICBC to fairly adjust and settle claims, rather than playing fast and loose with the truth. Extra court days, preparation and costs had to be devoted to dealing with the issue of liability when the Corporation had already accepted that it’s insured defendant was responsible for causing the subject accident. In a time where insurer’s like ICBC pay for ads that like to promote blame against claimants for rising claims costs, this case demonstrates that it is in fact ICBC that conducts itself in a way that adds unnecessary costs.

The Nixon Wenger legal team will be applying for special costs against the defendant and his insurer as ordered by Madam Justice Gropper; that decision will be an interesting one as well.

October 28, 2016

Powers of Attorney – Changes to an Old Favourite and not just for Seniors

Blog

Written by Chris Alveberg, Partner
Do you know what would happen to your home, financial affairs and other property (e.g., your finances, real estate, business) in the event that you suddenly suffered an accident (whether at work or otherwise) or illness (e.g., stroke)? Who would manage your property and financial affairs? Nobody, not even a spouse, has automatic legal authority over an adult’s financial or legal affairs, even if you become incapable.
Unfortunately, most commonly these considerations only occur as people advance in years and experience family friends or acquaintances who lose their ability to manage their financial affairs or to care for themselves without aid. Because of the length of time and cost involved if you have not planned for incapacity, a review of the options available is essential at any age.
On September 1, 2011, changes to the Power of Attorney law came into effect in British Columbia. However, if your existing document was validly made under the previous provisions it should still be valid, as existing Powers of Attorney were grandfathered under the new provisions.
Even though pre-existing Powers of Attorney may still be valid, when your appointed Attorney acts as your Attorney they will be governed by the new provisions and will have different powers and limitations. If you do not want those particular changes then you may have to revoke your existing Power of Attorney and make a new one on different terms.
Some of the most important changes include a restriction on how your Attorney can invest your property unless the Power of Attorney specifically provides otherwise. In addition, your Attorney will not be able to be paid for their duties as attorney, unless your Power of Attorney specifies a rate or amount of compensation. If there is no mention of such compensation, your Attorney cannot be paid even if they are spending significant time year after year looking after your affairs.
If you want your Attorney to have the ability to delegate certain of their powers (for example, preparing your income tax returns) under the new provisions you must specifically state that your Attorney has to ability to delegate.
Finally, under the new provisions your Attorney may make gifts, loans and charitable donations that you would have made, but only up to a maximum of $5,000 and only if you will have sufficient property left over to meet your needs (and anyone you are supporting). As a result, if you want your Attorney to be able to make more generous gifts (including to immediate family members and certain charities) then you will have to specify that in a new Power of Attorney.
Since there were many changes to the Power of Attorney law, it is a good idea to have a lawyer review your existing Power(s) of Attorney to confirm that they are still valid and reflect your current instructions. You should also be aware that if you decide to change the people that you have appointed as your Attorney the new provisions require you to give written notice to each Attorney of the cancellation of the existing Power of Attorney.
But your Attorney cannot make medical or health care decisions for you. For these decisions, you will need to consider preparing a Representation Agreement. The Representation Agreement Act allows you to appoint someone as your legal representative to handle your personal care, medical and health care decisions if you are unable to make them on your own.

August 25, 2016

Property Transfer Tax: Some Recent Changes

Wills and Estates, Blog

Written by Leanne Rutley, Associate

Effective February 17, 2016, the provincial government announced a few significant changes to the Property Transfer Tax (“PTT”):
1. in an effort to promote new home construction, there is no PTT on new homes (to be used as the buyer’s principal residence) having a price of up to $750,000.00; and
2. there is a new tier of 3% for all properties (both residential and commercial) over $2,000,000.
PTT remains at 1% of the first $200,000 and 2% for that part of the price over $200,000 up to $2,000,000 when the new tier of 3% is applied. There are no changes to the First Time Home Buyer’s exemption criteria.
To qualify for the new home exemption, the property must be registered at the Land Title Office after February 16, 2016 and the buyer must be an individual (i.e. not a company) who is a Canadian citizen or permanent resident. The property must be located in BC, be used as the buyer’s principal residence, have a fair market value of $750,000 or less and be 0.5 hectares (1.24 acres) or less in size.
A new home includes, among other things, a house constructed and affixed to vacant land, a new apartment in a newly built condominium building, a manufactured home affixed to vacant land, and a house converted from an existing improvement on land (e.g. a warehouse converted into a home or apartments).
The buyer must move into the new home within 92 days after the purchase, and must occupy the home as their principal residence for at least the remainder of the first year. If an owner passes away or must move due to a separation within that first year, the exemption may still apply.
Buyers of new homes are entitled to the new home exemption even if they have just moved from another province. This differs from the First Time Home Buyer’s exemption which has a residency requirement – the First Time Home Buyer must have lived in BC for at least 12 consecutive months before they take ownership of their home. In both cases, the buyer must live in the home for at least 1 year after the purchase. The PTT branch will send the buyer a letter at the end of the first year to request confirmation of the residency requirements.
Although buyers may qualify for the First Time Home Buyer’s exemption only once, there is no limit to the number of times a particular buyer can qualify for the PTT exemption on new homes, provided that the exemption criteria are met. A buyer cannot apply for both the FTHB exemption and the new home exemption on the same purchase.
With the new home exemption up to $750,000, this represents savings to the buyer of up to $13,000.00. There is a partial exemption for properties having a fair market value over $750,000 but less than $800,000. There is no exemption for a new home having a fair market value of more than $800,000. For example, if the property is valued at $805,000, there is PTT on the entire price – not just on the last $5,000. There is also no exemption for new or used homes that are purchased as investment or rental properties.

June 9, 2016

Managing Business Risk: Use Employment Agreements

Business Law, Blog

Written by Andrew Powell, Partner

From an employer’s perspective, employees are a necessary evil. A growing business cannot exist without employees, but it is vital for any business owner to remember that employees are not invested in the business that employs them. Employees are not owners. The relationship of employers to employees is very much a contractual one. Employees provide a service in exchange for money, so in a very real sense, the business is the customer of the employee.
The employment relationship constitutes a very special type of contract. Although for many purposes at law employees are differentiated from independent contractors, they are in fact in a contract with their employer. What makes the employment contract a little unique is that many of its terms are imposed by law – either under legislation such as the Employment Standards Act (for non-union workers) and the Workers Compensation Act, or because of common law principles that affect the employer-employee relationship. In either case, many of these terms of an employment arrangement may not be understood or even be known by either party. For this reason, when an employment relationship breaks down, there may be liabilities faced by employers that were unexpected and for which the employer may well be completely unprepared.
A typical example, frequently litigated, is the calculation of severance pay. Severance pay is an amount of money paid to a worker who has been dismissed without cause, and it is intended to cover that employee’s lost wages for enough time for that employee to reasonably be able to find similar employment. Generally, it is assumed that an employee will become more secure, more specialized, and more highly-compensated the longer that he or she occupies a position, so they will require more time to find equivalent positions if they are let go. Longer-term employees require longer notice periods, and consequently higher severance payments in lieu of that notice period.
Under s.63 of the Employment Standards Act, the employer’s liability for severance is one week’s wages after three months of employment, two week’s wages after twelve months of employment, and an additional one week’s wages per year of employment up to a maximum of 8 week’s wages.
Case law in British Columbia, however, has put quite a different light on the amount of appropriate severance pay. Although each case is determined individually, it would be more accurate to say that an employer’s real liability is closer to one month’s wages per year of service, to a maximum of about 24 months. This is a significantly greater liability than the one offered by the Employment Standards Act, and in the absence of a written employment contract, it is likely the one that will govern. A very important way to limit liability for severance pay, then, is to have a written employment agreement in place that confines severance pay to the amount set out in the Employment Standards Act.
Employment agreements can do much to help provide certainty and security in a number of ways, and can help cover exposure in areas that employers never anticipate being contentious until after the employment relationship breaks down and a dismissal becomes necessary for the business. Employment agreements can not only limit severance pay, they can define workplace responsibilities, determine compensation, and can even set out circumstances where employees can be dismissed without notice or severance pay. They can be tailored to any business or individual circumstance, and can be a very significant legal tool that a company can use to manage the consequences of its business decisions and take control of its own risk.

April 11, 2016

Are Gifts Given to your Child Also Gifts to your Child’s Spouse When They Split?

Blog

Written by Kylie Walman, Associate

Cabezas v. Maxim, 2015 BCCA 82 – Chiasson, Garson, Goepel, J.J.A.
In BC, gifts given to one spouse by a third party (like a parent) are not considered family property and the spouse who received the gift keeps it when the couple splits. But what happens when the other spouse says the gift was also intended for him/her – particularly where the gift is payments made on the couples’ mortgage by one of their parents? That was the question for the British Columbia Court of Appeal in Cabezas v. Maxim, 2015 BCCA 82, released on February 25, 2016.
In Cabezas, Mr. Maxim’s mother made substantial mortgage payments to pay off the couple’s home – which was in joint names. The parties sold the home after they split and the issue of the mortgage payments was important to determine how much each party would get out of the sale of the home. Mr. Maxim argued that the mortgage payments were gifts to him alone – as an advance on his inheritance – and he should get back all of that money. Ms. Cabezas argued that the payments were gifts to both of them and the sale proceeds should be divided equally.
The Court held that the intention of the parents at the time the gift was given is what matters in deciding whether the daughter-in-law should benefit. Although Mr. Maxim’s mother testified that she intended the payments to be an advance on her son’s inheritance, the Court didn’t accept that evidence. Instead, the court noted that the house was in both names; Mr. Maxim’s mother didn’t say the gift was for her son alone; and she gave similar gifts to her other children and their spouses. So, at the time of the gift, the court found that Mr. Maxim’s mother didn’t think about whether it would benefit her daughter-in-law, she simply wanted to help her son out with his expenses. The Court concluded that the gift was for both spouses and the sale proceeds were divided equally.
If you wish to give your adult children substantial gifts and want to keep their spouses from benefiting if the marriage breaks down – you need to ensure your intentions, at the time the gift is given, are stated clearly and in writing.

April 1, 2016

Airbnb & GST

Real Estate, Blog

Written by Krystin Kempton, Associate.

Airbnb is a website connecting people searching for short term accommodation with homeowners wishing to rent their homes or spare rooms. An increasingly popular alternative to hotels, Airbnb may bode well for many of us living in here paradise, as vacationers come to town for ski vacations in the winter and cottage life in the summer. Short term rentals—that is, rentals for less than 30 consecutive days—can lead to some extra pocket cash. However, that extra pocket cash leads to taxes.

First of all, rental income is added to regular income and is taxed at the same rate. It is in the homeowner’s best interest to put aside reserves to avoid unwelcome surprises when income taxes are due. Homeowners also need to be aware of goods and services tax (“GST”) implications. If rental income exceeds $30,000 in one year, the homeowner must register with Canada Customs and Revenue Agency. As a GST registrant, the homeowner is obligated to charge and remit GST and file returns. The homeowner may recover GST paid on operating expenses and capital improvements by claiming input tax credits (“ITCs”), based on the extent to which the property is used for taxable rentals.
If a homeowner uses his or her property for short term rentals and wishes to sell the property, it is important to determine whether GST will apply to the purchase of the property. GST is payable if:

– the seller has claimed ITCs for GST on the purchase of the property or improvements on the property;

– the property is used less than 50% of the time as the seller’s place of residence and all or substantially all (90% or more) of the rentals of the property are for periods of less than 60 days;

– the property is capital property (i.e., not designated as the owner’s primary residence and therefore subject to a capital gain or capital loss on disposition), and the property is used primarily in a rental-income business carried on by an individual or a personal trust with a reasonable expectation of profit and the owner is not a GST registrant; or

– the property is capital property and the property is used primarily in making taxable short-term rentals by an individual or a personal trust that is a GST registrant, even if that owner is not engaged in a business carried on with a reasonable expectation of profit.
If any of the above apply, the purchase contract for the property will need to specify whether GST is added to the purchase price or included in the purchase price to ensure the price has been negotiated properly by the buyer and seller and avoid lost revenue by the seller. If the purchaser is a GST registrant and intends to use the property for short term rentals, an ITC may be available to offset some or all of the GST payable on the property purchase. If the purchaser uses the property primarily (more than 50%) for personal use, that individual is not eligible to claim an ITC for GST paid or payable on the property purchase, even if there will be some taxable short term rentals of that property. Also, if the purchaser changes the use of the property to his or her personal use, the purchaser may be required to account for the GST.
Provided the homeowner is aware of tax obligations and implications of short term rentals on an eventual sale of the property, Airbnb offers a lucrative option for homeowners to offset mortgages and join the sharing economy.

March 31, 2016

Partnership Perils and the Benefits of a Partnership Agreement

Blog

Written by Will Spisso, Associate
For most entrepreneurs, starting a new business is a time filled with excitement and optimism. However, when people work together to start or operate a business, it can have the unintended result of forming a partnership. Unfortunately, this often leads to disputes later on, especially if the business partners decide to part ways.
Forming a partnership is simple and can occur even if it is not the parties’ intention. Under the Partnership Act of British Columbia, a partnership is defined as “the relation which subsists between persons carrying on business in common with a view of a profit.” No formal agreement is necessary to create the partnership. If two or more people start working together on a business with the goal of making a profit, it is likely that a partnership will exist. However, for the reasons discussed below, it is important that businesspersons do not enter into accidental partnerships. Also, if you intend to form a partnership, you can avoid serious pitfalls by entering into a partnership agreement.
A partnership is not a legal entity separate from its partners. This means that a partner is personally liable to the full extent of his or her personal assets for the debts and obligations of the partnership. If one partner enters into a contract, the other partners are also liable and required to perform all obligations under the contract in connection with the partnership business. Furthermore, the partners are liable for the actions of the other partners. For example, if someone sues the partnership, each partner will be fully and personally liable if the lawsuit is successful. This is the case, even if only one partner was the cause of the lawsuit.
Another feature of a partnership is that it can be dissolved almost as easy as it can be formed. Unless otherwise stated in an agreement among the partners, the partnership can be dissolved by any partner giving notice to the others of his or her intention to dissolve the partnership. This can create an incredibly difficult situation when one or more partners wish to continue with the business, while another partner wishes to exit and see the partnership dissolved.
In addition to stopping a functioning business dead in its tracks, the dissolution of a partnership can also pose significant problems when it comes to dividing the partnership assets if there is no agreement in place identifying who the assets belong to. By default, no partner has a right or entitlement to take specific assets that he or she may have contributed to the partnership. Therefore, if a partner does not want a particular asset to become partnership property, this should be documented in an agreement among the partners.
The issues above highlight some of the most important reasons why it is recommended to have a partnership agreement. In a partnership agreement, the partners can:

· outline the roles of particular partners, including their duties and obligations;

· state whether insurance is required for the partnership in respect of particular activities;

· determine which partners may enter into contracts on behalf of the partnership;

· set out how partnership assets will be divided upon the dissolution of the partnership;

· establish what is required for the dissolution of the partnership; and

· break down how partnership profits and liabilities will be allocated among the partners.

It is usually only once the business partners have a dispute or when one partner wants to leave the business that they finally approach a lawyer for advice. At that point, however, the lawyer’s options may be limited to trying to help the parties negotiate and reach a compromise on how the dispute will be settled. If there is no partnership agreement in place, and one partner is set on dissolving the partnership, this can effectively end the business.
Consequently, to avoid unnecessary disputes in a partnership, it is helpful to have a partnership agreement in place at the time the partnership is formed. Though this may result in initial legal costs, it can save a great deal of time, money, and frustration later on when a dispute arises among the partners. Moreover, if the business relationship does not work out, it can provide a clear roadmap for how the partnership will be dissolved and how its assets will be distributed. Though this may not be the outcome the optimistic businessperson hoped for when starting the business, it can provide that same person the opportunity to move on and start again with an even better business endeavour.

March 18, 2016

Electronic Signatures: Are they legal? Are they safe?

Real Estate, Business Law, Blog

Written by Nixon Wenger Lawyer, Dan Poulin.

Not all contracts need to be written down or signed, an oral or spoken contract can generally be enforced by our court system, as long as there is enough evidence to convince the court that a contract actually existed. However, there are certain types of contracts which require that the parties sign the contract in order for it to be enforceable by our court system, such as Real Estate contracts. You may wonder whether a signature requirement means a person needs to put pen to paper, or if some kind of electronic signature would have the same effect. Further, you may wonder whether an electronic signature would be any more or less persuasive in court as proof that there actually was a contract.
First, electronic signatures have the same legal effect as handwritten signatures. Most provinces in Canada have passed legislation which clarifies that electronic signatures may be used, including the Electronic Transactions Act in British Columbia. This Act defines an electronic signature as “information in electronic form that a person has created or adopted in order to sign a record and that is in, attached to or associated with the record”. Therefore, an electronic signature does not need to look like a traditional signature, although sometimes images that have the appearance of a traditional signature are used.
The next question is whether an electronically signed document would be better or worse than a traditional signature if you needed to prove in court that a contract was signed. The answer is that neither electronic or traditional signatures are inherently better than the other, it depends on the circumstances in which the signature was made. For example, you may receive a contract document that appears to be signed by a person you expected to enter a contract with from a public fax service number. Alternatively, you may have the other party come to sign the contract document personally and also bring some other people to witness his signature. In the second scenario you would have much stronger proof that the other party entered the contract, as you would have the original document and people that could confirm the document was signed by the right person.

Similarly, some electronic signatures would be much better proof in court than others, as they can range from simply typing your name at the end of an email (which may not be very strong evidence, particularly if other people have access to your email) to verifiable digital signatures that can only be attached to electronic documents after the signor signs up for the digital signature service and passes verification procedures such as entering a password before signing. In fact, with the use of digital signature services like AuthentiSign or DocuSign some real estate agents and lawyers may not require a witness signature, as the digital signature service itself acts as a type of witness.
There is no need to be afraid of electronic signatures with respect to legality. However, just like regular signatures, you should ensure that if there would be significant consequences to a signature being challenged, there are safeguards in place that will provide you the evidence you need to enforce the legal document.

March 3, 2016