Freezing Order Lawyer

Mareva Injunctions, Asset Preservation & Emergency Commercial Relief

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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.

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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.

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How We Help

Civil Litigation Services

Commercial Litigation Counsel

From commercial disputes and estate conflicts to defamation and business sabotage, we protect our clients through immediate legal intervention.

Real Estate, Title Fraud, and Transaction-Freeze Injunctions

Real estate fraud and title disputes frequently involve urgent threats to property ownership, secured interests, enterprise value, and asset preservation. ME Law represents property owners, lenders, developers, investors, and sophisticated stakeholders in high-stakes real estate fraud litigation and emergency injunction proceedings throughout Ontario.

Urgent Interlocutory and Interim Injunctions

ME Law is a litigation-only firm with extensive experience handling interlocutory injunctions in commercial, real estate, employment, and property disputes. Litigation is all we do.

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

Strategic Commercial Arbitration & Dispute Resolution

Securing a $50M+ Mareva Injunction for a Silicon Valley Startup

Strategic Resolution of $5M+ Shareholder Disputes Across Litigation and Arbitration

Strategic Resolution of $20M Corporate Dispute and $8M+ Estate Succession Matter

Strategic Litigation Leadership in a $15M+ Corporate and Family Dispute

Securing a $2M+ Property Interest After an 8-Day Civil Trial

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.

Mareva Injunctions & Freezing Order Applications

Urgent Without-Notice Asset Preservation Motions

Worldwide Freezing Order & Cross-Border Preservation Strategy

Fraud, Asset Diversion & Dissipation Response

Freezing Relief in Shareholder, Oppression & Governance Disputes

Freezing Relief in Fiduciary Duty & Corporate Opportunity Cases

Receivership, Receiver-Manager & Court-Supervised Preservation Relief

Tracing, Asset Identification & Recovery Strategy

Norwich, Disclosure & Information-Gathering Support for Preservation Motions

Anton Piller & Evidence-Preservation Relief in Emergency Cases

Post-Closing, Earn-Out & Transaction-Related Asset-Freezing Disputes

Return Motions, Variation Motions & Ongoing Freezing-Order Management

Clear Guidance. Strong Advocacy.

What we do:

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Frequently Asked Questions

Becoming a Client

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How do I become a client of ME Law?

Becoming a client of ME Law begins with a complimentary intake call and proceeds through a conflict check, a formal consultation with a lawyer, and, if you decide to retain the firm and ME Law agrees to act, a written Retainer Agreement. Once the agreement is executed and the required retainer is received, ME Law opens the file and begins the agreed legal work.

The first step is the initial intake call. This is a preliminary conversation with an intake specialist, not the substantive legal consultation itself. The purpose is to understand the general nature of your matter, identify the type of dispute involved, gather preliminary information, and determine whether the matter falls within ME Law’s areas of practice.

At this stage, the firm is screening the matter so that the appropriate next step can be identified. If the matter appears to be one ME Law may be able to assist with, the process moves to a conflict check before detailed legal advice is provided.

If you want to understand why that step is required, see Why is a conflict check necessary before a consultation?.

The conflict check is conducted to determine whether ME Law has a professional conflict that would prevent the firm from acting. The process is governed by the Law Society of Ontario professional obligations and is intended to protect confidentiality, independence, and loyalty. You may be asked to identify the relevant parties so that those names can be checked against the firm’s records.

Once the conflict check is cleared, the next stage is a formal consultation with a lawyer. This is different from the preliminary intake call. The consultation is the substantive meeting in which the lawyer reviews your situation in more detail, answers questions, discusses preliminary legal options and strategy, and explains what the next steps may look like.

For a fuller explanation of the meeting itself, see What is a consultation at ME Law?.

The onboarding process can therefore be understood in five stages:

Initial intake call.
ME Law gathers preliminary information, identifies the nature of the matter, and determines whether it falls within the firm’s practice areas.
Conflict check.
The relevant party names are reviewed to determine whether a conflict of interest prevents ME Law from proceeding.
Consultation with a lawyer.
Once cleared, you meet with a lawyer, either in person or remotely, for a more detailed assessment of the matter and the legal options that may be available.
Retainer and engagement.
If you decide to proceed and ME Law agrees to take on the matter, the firm provides a Retainer Agreement setting out the scope of work, estimated costs, and billing structure. The scope is defined according to the work that is actually required rather than assumed to cover every possible step in the dispute.
File opening and legal work.
Once the Retainer Agreement is executed and the required retainer is received, the file is formally opened. The lawyer can then begin the agreed work, which may include developing a case strategy, drafting pleadings, engaging in negotiations, or preparing for court proceedings, depending on the mandate.

Becoming a client is therefore not the same thing as making an inquiry or completing an intake call. It also does not occur merely because a consultation has been booked. The formal engagement stage matters because it defines what ME Law has agreed to do, how the work will be billed, and what the client and firm should expect from the relationship.

The consultation is also where the proposed scope of the engagement can be discussed. Depending on the matter, that may involve advice on a defined issue through a limited-scope retainer or broader ongoing representation through a full-scope retainer. The appropriate structure depends on the record, complexity, procedural stage, and work required.

If your matter is urgent, explain that during the intake process so the firm can assess timing and lawyer availability. See How quickly can you schedule an initial consultation? for how consultation scheduling is handled after intake and conflict clearance.

ME Law’s onboarding process is designed to move from preliminary screening to conflict clearance, substantive legal assessment, and then a clearly defined engagement. The purpose is to ensure that the firm understands the matter, can act without a professional conflict, and has agreed with you on the scope of the work before substantive representation begins.

Contact ME Law to start the intake process and discuss whether your matter is one the firm may be able to assist with.

What are the typical steps from first contact to retaining ME Law?

The process typically moves through five stages: an initial intake call, a conflict check, a consultation with a lawyer, a formal Retainer Agreement, and then file opening and the start of the agreed legal work. Each stage has a different purpose, so contacting ME Law does not automatically mean that the firm has been retained.

1. Initial intake call

The process begins with a complimentary intake call. An intake specialist gathers preliminary information about the dispute, identifies the parties involved, and considers whether the matter falls within ME Law’s areas of practice.

This is an initial screening step rather than the substantive legal consultation. If you want the broader overview of becoming a client, see How do I become a client of ME Law?.

2. Conflict check

If the matter is potentially suitable for the firm, ME Law conducts a conflict check before moving into substantive discussions. Relevant party names are checked against the firm’s records to determine whether professional obligations prevent ME Law from acting.

For more detail on the purpose of this step, see Why is a conflict check necessary before a consultation?.

3. Consultation with a lawyer

Once the conflict check is cleared, a formal consultation can be scheduled. The consultation may take place in person or remotely and is the stage at which the lawyer reviews the matter in greater depth, discusses preliminary legal options and strategy, and considers what further work may be required.

This is distinct from the initial intake call. What is a consultation at ME Law? explains the scope of that substantive meeting in more detail.

4. Retainer and engagement

If you decide to proceed and ME Law agrees to accept the mandate, the firm provides a written Retainer Agreement. It identifies the agreed scope of work, billing structure, and other terms governing the engagement.

Depending on the matter, the engagement may be structured as a limited-scope retainer for defined work or as broader ongoing representation. The lawyer-client engagement begins according to the terms of the executed retainer rather than merely because an inquiry or consultation has taken place.

5. File opening and next steps

After the Retainer Agreement is executed and any required retainer funds are received, ME Law can formally open the file and begin the work within the agreed mandate.

Depending on the dispute, that work may include developing litigation strategy, reviewing evidence, drafting pleadings, engaging in negotiations, or preparing for proceedings before the Ontario Superior Court of Justice.

The purpose of this staged process is to ensure that the matter is screened appropriately, conflicts are addressed, the legal issues are assessed, and both the client and ME Law understand the scope of the engagement before substantive representation begins.

Contact ME Law to begin the intake process.

What information do I need to provide for a conflict check after the initial call?

After the initial intake call, ME Law will ask you to identify the parties involved in your matter so the firm can complete a conflict check before receiving detailed confidential information or moving to a substantive consultation. The purpose at this stage is to establish who is involved, not to conduct a full review of your case.

The conflict check is part of ME Law’s intake and onboarding process. Before a lawyer can proceed with substantive discussions, the firm must determine whether it currently represents, previously represented, or holds confidential information relating to a party whose interests may conflict with yours.

ME Law’s conflict-check obligations arise under the Law Society of Ontario’s Rules of Professional Conduct and form part of the professional duties governing independence, loyalty, and confidentiality.

If you want a fuller explanation of the legal and ethical reason for this process, see Why is a conflict check necessary before a consultation?.

What should you provide?

At this stage, you should provide the names of the relevant parties involved in the dispute or proposed engagement. The objective is to give ME Law enough identifying information to run the appropriate check against its records.

Depending on the matter, there may be several parties whose involvement needs to be identified before the conflict check can be completed. The important point is to disclose the relevant party names accurately so the firm can determine whether a professional conflict exists.

You generally should not use the conflict-check stage to send a large volume of confidential documents or provide an extensive substantive account of the dispute before ME Law confirms that it is able to proceed. The conflict check comes before the detailed legal assessment.

The typical sequence is:

Initial intake call — ME Law gathers preliminary information about the nature of the matter.
Party identification — you provide the names required for the conflict check.
Conflict review — ME Law checks its records for potential professional conflicts.
Conflict clearance — if no conflict prevents the firm from proceeding, the matter can move to the next stage.
Consultation — detailed documents, facts, legal issues, strategy, and possible next steps can then be addressed through the substantive consultation process.

This distinction is important because completing a conflict-check form does not itself create a retainer or mean that ME Law has agreed to represent you. It is a preliminary professional safeguard within the intake process.

For the broader onboarding sequence, see How do I become a client of ME Law?. Once the conflict process is complete, What is a consultation at ME Law? explains what happens at the substantive legal assessment stage.

Contact ME Law to begin the intake process and provide the party information required for a conflict check.

What happens during the initial intake call with ME Law?

The initial intake call is a complimentary preliminary conversation with an ME Law intake specialist. Its purpose is to understand the general nature of your matter, gather the information needed to assess whether it falls within the firm’s areas of practice, identify the relevant parties, and determine the appropriate next step.

The intake call is different from a substantive consultation with a lawyer. At this stage, ME Law is not conducting a detailed review of your evidence or providing a full legal assessment. Instead, the firm is gathering enough preliminary information to determine whether the matter is one it may be able to assist with and what must happen before a consultation can proceed.

For an overview of the complete onboarding process, see How do I become a client of ME Law?.

During the initial intake process, you may be asked to explain:

the general nature of the dispute;
who the relevant parties are;
whether litigation or another legal proceeding has already started;
whether there are immediate deadlines or urgent circumstances;
what type of assistance you are seeking from ME Law.

Identifying the parties is particularly important because the next step will ordinarily involve a conflict check under the Law Society of Ontario’s professional-conduct requirements. ME Law must determine whether a professional conflict prevents the firm from proceeding before receiving detailed confidential information or moving into substantive legal discussions.

For the practical information required at that stage, see What information do I need to provide for a conflict check after the initial call?.

Once the conflict check is completed and the firm is able to proceed, a formal consultation with a lawyer can be scheduled. That consultation is where the matter can be examined in greater depth, including the factual record, legal issues, preliminary strategy, and possible next steps.

The distinction matters: an intake call, a conflict check, a substantive legal consultation, and a Retainer Agreement are separate stages of the client-onboarding process. Completing the intake call does not by itself mean that ME Law has agreed to act or that a lawyer-client retainer has been established.

If you want to know how quickly the substantive lawyer meeting can be arranged after intake and conflict clearance, see How quickly can you schedule an initial consultation?.

Contact ME Law to begin the intake process.