Freezing Order Lawyer
Mareva Injunctions, Asset Preservation & Emergency Commercial Relief
Successful Litigation Cases Handled
Litigation, Mediation, Trial - Focused
Years of Combined Legal Experience
In Handling Complicated Disputes
Why You Need Legal Help with a Freezing Order
Freezing-order litigation begins where ordinary civil timing is no longer good enough. The problem is not simply that a claim exists. The problem is that money, shares, receivables, crypto, sale proceeds, or other realizable assets may be moved, concealed, dissipated, or restructured beyond practical reach before the court can determine the merits.
That is why freezing-order work must be approached as preservation litigation, not generic injunction practice. In Ontario, interlocutory injunctions remain governed procedurally by Rule 40 of the Rules of Civil Procedure and substantively by section 101 of the Courts of Justice Act. Rule 40 continues to permit interlocutory relief in a pending or intended proceeding, allows without-notice orders only for short periods subject to extension rules, and requires an undertaking as to damages unless the court orders otherwise. Section 101 continues to authorize interlocutory injunctions, mandatory orders, and receivers where it appears just or convenient to do so.
A freezing order lawyer in Toronto must therefore do more than draft an urgent motion record. Counsel must determine whether the real risk is dissipation, concealment, diversion, or structural insulation; whether the right first step is a Mareva injunction, a receiver, tracing relief, or a related disclosure tool; whether without-notice relief is justified; and whether the requested order is strong enough to preserve value without becoming so broad that it cannot survive scrutiny on the return of the motion.
These cases commonly arise in fraud claims, fiduciary-duty disputes, shareholder and oppression proceedings, post-closing conflicts, confidential-information disputes, and other high-stakes business litigation where recoverability is under immediate threat. The practical objective is not merely to obtain a dramatic order. It is to preserve the asset base, stabilize the dispute, and protect the client’s ability to enforce a future judgment in a meaningful way.
Years of
combined
legal
experience
ME Law - Civil Litigation Law Firm
WHO WE ARE
ME Law is a litigation-only firm that acts in urgent commercial injunctions, Mareva injunctions, and freezing-order applications across Toronto and Ontario.
We are retained when the stakes have moved beyond liability and into recoverability: when a founder, principal, debtor, counterparty, fiduciary, or business adversary appears to be moving assets; when value may be leaving the jurisdiction or passing through affiliates; when a governance conflict is accelerating into asset diversion; or when a claimant needs decisive preservation relief before ordinary litigation timing makes the case commercially hollow.
Our role is not merely to seek an order freezing assets. It is to assess the true risk landscape, marshal the evidentiary record with speed and discipline, design a workable preservation order, and align the interim relief with the broader litigation and enforcement strategy that follows.
Whether the underlying dispute involves fraud, misappropriation, breach of fiduciary duty, shareholder oppression, corporate-governance conflict, post-transaction misconduct, confidential-information misuse, or a broader recovery-driven commercial claim, we bring legal rigor and commercial judgment to the problem.
How We Help
Civil Litigation Services
Why Choose Us
Premium Litigation Services:
Quality over quantity for selected clients in complex litigation matters
Selective Focus
We act for a select group of clients in high-stakes litigation, dedicating focused time and strategic attention to each matter to ensure precise, results-driven advocacy.
Limited Caseload
By limiting our caseload, we provide bespoke, high-level representation, where no detail is overlooked and every legal step is carefully considered. Quality over quantity is embedded in our ethos.
Strategic Execution
Our limited-file approach enables us to deliver thorough, strategic legal work on every matter. We don’t offer surface-level service – we provide clarity, focus, and substance.
Beyond Expectations
Our lawyers invest considerable time in legal analysis, research, and continuous training. This ongoing development allows us to stay ahead and deliver outcomes that often exceed clients’ expectations.
Clients’ Success Stories
Our cases
How We Work
What To Expect
Clear and Strategic Guidance
Transparent and well-informed advice is provided to help navigate your options and achieve the best possible outcome.
Proactive Client Engagement
Clients can expect consistent communication and dedicated attention to ensure their needs are fully understood and addressed.
Meticulous Attention to Details
Every detail is carefully considered, and strategic oversight is provided to guide clients toward a favorable resolution.
Experienced. Strategic. Results-Oriented.
Freezing orders are among the most exacting forms of interlocutory relief in commercial litigation. They are powerful because they can materially reshape the litigation landscape at the outset. They are exacting because they are intrusive, urgent, and closely scrutinized. They require speed, but not haste; aggression, but not overreach; precision, but not timidity.
The governing Canadian principles remain clear. In Aetna Financial Services v. Feigelman, the Supreme Court of Canada treated Mareva relief as an exceptional remedy aimed at freezing exigible assets within the jurisdiction where there is a justiciable cause of action and a genuine risk of disappearance of assets. In RJR-MacDonald Inc. v. Canada (Attorney General), the Court articulated the familiar interlocutory-injunction framework that continues to shape urgent relief analysis more broadly. Those authorities remain foundational to serious asset-preservation work.
At ME Law, we act in freezing-order matters arising from fraud, civil conspiracy, fiduciary misconduct, corporate-opportunity diversion, shareholder and oppression disputes, dissipation of sale proceeds, earn-out conflicts, asset stripping, and other commercial disputes where the recoverable asset base may be deteriorating in real time. Our focus is always the same: preserve value, prevent strategic dissipation, and improve the client’s practical enforcement position before the merits process runs its full course.
Where the dispute is sufficiently complex, urgent, or enterprise-critical, Toronto Commercial List discipline may also matter. The current Toronto Region Consolidated Practice Direction, effective October 14, 2025, continues to include a dedicated Commercial List section and remains a relevant procedural framework for complex commercial matters in Toronto.
Freezing-order work also rarely stands alone. In the right case, it sits alongside tracing strategy, receivership analysis, disclosure applications, preservation of documentary evidence, and early thinking about how the eventual judgment will actually be enforced. That is why the strongest freezing-order counsel do not approach the motion as an isolated event. They approach it as the first move in a broader recovery architecture.
FREEZING ORDER LAWYERS YOU CAN RELY ON
We represent claimants, companies, boards, investors, family offices, lenders, and stakeholders seeking urgent asset-preservation relief in high-stakes commercial disputes. That includes Mareva injunctions, without-notice freezing-order motions, return motions, variation motions, related tracing strategy, preservation relief in shareholder and oppression litigation, and emergency applications in fraud, fiduciary-duty, and asset-diversion cases.
Our team understands that sophisticated clients are not looking for procedural theatre. They are looking for counsel who can identify when freezing relief is genuinely warranted, move quickly enough to matter, and frame the order in a way that preserves value without compromising the long-term case. That requires judgment about evidence, timing, scope, return-motion risk, commercial optics, and the downstream enforcement objective.
Commercial injunction and emergency litigation are core areas of our practice. We know how to assess dissipation risk, how to structure urgent injunction records, how to integrate freezing relief with receivership and tracing strategy, and how to position the matter so that interim success contributes to — rather than distracts from — the client’s ultimate recovery. Where the underlying dispute is corporate in nature, Ontario’s Business Corporations Act continues to provide an oppression remedy in section 248 and broad interim and final remedial authority, which can become highly relevant where asset movement is tied to shareholder or governance misconduct.
Our Commitment
We approach freezing-order litigation with precision, discretion, and resolve. Our role is not simply to ask the court to freeze assets. It is to identify what must be preserved, why it is truly at risk, how the order should be framed, and what additional steps may be necessary to convert interim protection into meaningful recovery leverage.
Where appropriate, that may include a Mareva injunction, related injunctive relief, a receiver or receiver-manager under section 101, tracing-oriented relief, return-motion advocacy, or broader emergency commercial litigation strategy. We act with urgency where the facts justify it, but always with close attention to the evidentiary record, the undertaking as to damages, the durability of the order, and the broader litigation consequences of the relief sought.
With us on your side, a strong claim need not become a commercially empty one because assets were permitted to disappear before judgment.
Clear Guidance. Strong Advocacy.
What we do:
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- intake@melaw.ca
- (416) 923-0003
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