Expert Witnesses
Cross-Border
Class Actions
in Canada
Difficulties in the coordination of class action proceedings in
different provinces of Canada can bring uncertainty to
cross-border class actions
By Tim Buckley, Robert E. Charbonneau & Julia Mercier; Borden Ladner Gervais LLP
C
Class action and conventional lawsuits in the United
States will continue to spawn class actions in Canada.
This is not surprising in light of the downturn in
integrated securities and capital markets, as well as
the North American or worldwide distribution of
products manufactured or designed in the United
States. The United States’ and international counsel
often direct the defence of worldwide litigation and
must consider different strategies to defend related
litigation in Canada.
This article will review considerations affecting
cross-border class actions in Canada against the
backdrop of unsettled Canadian law concerning the
efficacy of Canadian national classes (similar considerations may apply to conventional or multi-district
litigation in the United States and class actions in
Canada). Canadian jurisdictions have not yet settled
principles permitting the certification and administration of national class actions in Canada. The
uncertainty impacting domestic actions clouds the
analysis of the enforceability of international class
action proceedings and promotes the proliferation of
parallel class actions in Canada.
International entities attempting to adjudicate or
settle Canadian plaintiff class member rights must
consider whether these rights may be effectively and
finally adjudicated in a foreign proceeding or through
the use of a Canadian national or multi-jurisdictional
class (i.e. certification classes composed of persons
present in the province in Canada where the class
action is commenced and persons resident in other
provinces of Canada) in a proceeding in one or more
provinces of Canada. The interests of potential target
defendants may vary — in some cases to limit claims by
putative class members, and in other cases to adjudicate or settle the rights of as many class members as
possible. Defendants, who are taken to judgment or
settlement in a class action, are interested in obtaining
a result that precludes future actions being initiated
by class members in other provinces in Canada.
The analysis of the preclusive effect of an international class action judgment or settlement in Canada
is complicated because principles of class action
jurisdiction and enforcement are in their infancy
in Canada and the decisions of appellate courts are
sparse (modern principles of the enforceability of
foreign money judgments against defendants who are
neither legally present in the jurisdiction of the forum
or have formally attorned to the jurisdiction of the
forum have been developed since Morguard Investments
Ltd. v. De Savoye, 1990 CanLII 29 [S.C.C.] and Beals v.
Saldanha, 2003 SCC 72 [CanLII]). Further, Canadian
courts have not settled the issue of the preclusive effect
of class action certification orders, class action settlement orders or class action judgments rendered by
one provincial superior court in a different province.
Simply stated, the preclusive effect of international
class action settlements and judgments will remain
unsettled while Canadian courts attempt to settle the
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Class Actions
same interprovincial issues.
By way of overview, the trial or settlement of the
claims of Canadian claimants by way of an international class action is not common. Canadian plaintiffs
customarily bring proceedings in Canada that are
similar to existing conventional actions or class actions
in the United States. As a matter of developing practice,
internationally negotiated settlements affecting the
rights of Canadian claimants or separately negotiated
settlements are customarily brought to the courts
of Canadian provinces for approval in a parallel
Canadian class action. There is considerable variation in practice in the number of provincial courts
that are asked to approve settlements.
Brief Highlights of Canadian Procedure
Canada does not have a single class action statute
or law. Nine of ten provinces have class action statutes
governing proceedings in their jurisdiction. In
addition, the federal government has enacted rules
governing class actions, but these only apply in the
Federal Court (a statutory court with limited subject
matter jurisdiction. A small number of class proceedings against the Canadian Federal government
proceed in the Federal Court.).
The analysis of the legal position of a plaintiff or
defendant in a proceeding in Canada may be further
complicated by the application of common law in nine
provinces and three territories of Canada and the
distinctly different civil law in the populous province
of Québec.
provinces and in Québec with the intention of moving
the action forward to settlement or trial in only one
province or possibly two provinces (if the substantive
law of Québec is different). Putative class members
may be folded into the class of the dominant proceeding as a multi-jurisdictional class emerges and
proceeds as the dominant action.
Costs
In several Canadian provinces, successful parties in
class actions can be awarded a significant portion of
their legal fees and disbursements to be paid by the
unsuccessful party. Legislation in several provinces is
cost neutral and the courts are prohibited from awarding costs to any party, except in cases of vexatious,
frivolous or abusive conduct. Plaintiff counsel may
be attracted to these jurisdictions particularly where
their prospects are uncertain.
Certification of Class Actions
International counsel are often surprised by the
breadth of cases certified in Canada. The certification requirements in the Canadian common law
provinces are very similar. For example, the criteria in
Ontario are: (a) the pleadings must disclose a cause of
action; (b) there is an identifiable class of two or more
persons that would be represented by the representative plaintiff or defendant; (c) the claims or defences
of the class members raise common issues; (d) a class
proceeding would be the preferable procedure for
the resolution of the common issues; and (e) there is a
representative plaintiff or defendant (Class Proceedings
Act 1992, S.O. 1992, c.6, s.5).
Canadian courts do not have a system or method
of supervising multi-province litigation, but ad
hoc arrangements have been designed in a limited
number of cases (for example, see the residential
schools litigation, including Baxter v. Canada [Attorney
General], 2006 CanLII 41673 [ON S.C.]). As a result,
plaintiffs often bring parallel or competing actions in
one or more provinces. Competing actions in a single
province can be resolved through carriage motions,
but there is no straightforward mechanism to manage
competing claims against the same defendant in
different provinces.
The certification criteria under the Québec Code of
Civil Procedure may be summarized as follows: (a) the
members of the group must present similar, identical
or related questions of fact and law — i.e. there must
be one or more common issue(s) to be tried; (b) the
plaintiff must have asserted a prima facie case that is
not frivolous; (c) the number of class members must
be sufficient so that it would be impractical or impossible for each of them to join in the same action or to
allow one of them to represent the others by proxy;
and (d) the proposed representative plaintiff must be
an adequate representative for the members of the
group. The legislature did not adopt the “preferable
procedure” criterion applicable in Ontario.
On a practical level, while some class actions
have been brought in each province to ensure that
settlements or decisions are enforceable throughout
Canada, many class actions are brought by cooperating plaintiff counsel in one or more common law
Canadian certification criteria do not include
several of the most important barriers or hurdles
to certification under United States Federal Rule of
Civil Procedure 23, particularly requirements for
predominance of common issues of fact and law
Multi-Province Litigation
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Expert Witnesses
and typicality of claims. The numerosity criterion is
applied in Québec to a certain degree.
The common issue criteria applied by many judges
in Canadian courts is not a high legal hurdle. An
issue can be a common issue even if it makes up a
very limited aspect of the liability question and even
though many individual issues remain to be decided
after its resolution (Sauer v. Canada [Agriculture], 2008
CanLII 43774 [ON S.C.], para 37). For example, international counsel may be surprised that certification
has been granted in a few cases in the context of
personal injury claims allegedly arising from the use
of pharmaceutical products despite individual issues
including the warnings provided, the knowledge of
different learned intermediaries who prescribed the
product, the differing medical histories of the plaintiffs, whether the plaintiffs followed directions as to
use and differing injuries. (Certification of one recent
case is under appeal).
As a result, conventional proceedings in the United
States or multi-district litigation in the United States
are often litigated as class actions in Canada.
Enforcement of International Class
Action Settlements and Judgments
The Supreme Court of Canada has not considered
the preclusive effect of an international class action
judgment or settlement. The Ontario Court of Appeal
considered this issue in Currie v. McDonalds Restaurants of Canada Ltd. et al. An Ontario resident brought
a class action in Ontario in the face of the settlement
of a class action brought on behalf of American and
international class members and approved by the
courts of the state of Illinois (the “Boland judgment”).
Defendants brought a motion in Ontario to dismiss
the Currie action as an abuse of process. The Ontario
Court of Appeal declined to dismiss the Currie action
because of the inadequacy of notice of opt out rights
provided to Canadian class members in the Boland
action. (Of interest, the Court of Appeal elevated the
issue of adequacy of notice to one going to the issue
of jurisdiction and held that Ontario court should not
recognize and enforce the Illinois judgment against
the non-attorning Canadian class members.)
The court decided that provided there is a real
and substantial connection linking the cause of
action to the foreign jurisdiction, the rights of nonresident class members are adequately represented,
and non-resident class members are accorded procedural fairness including adequate notice then it may
be appropriate to attach jurisdictional consequences
to an unnamed plaintiff’s failure to opt-out. In those
circumstances, failure to opt-out may be regarded
as a form of passive attornment sufficient to support
the jurisdiction of the foreign court (see Currie, para
30. The court immediately qualified that statement
by stating that the exact limits of what constitutes
a reasonable assumption of jurisdiction cannot be
rigidly defined and that it may be easier to justify the
assumption of jurisdiction in interprovincial cases,
rather than in international cases).
Production and
discovery in
Canadian class
actions are often
preceded by
production and
depositions in
the actions in the
United States.
The position of claimants and the nature of the
underlying transaction or their claim must be considered by the enforcing court. The court distinguished
between the position of class action members who
engage in cross-border transactions with foreign
entities and who could reasonably expect that legal
claims arising from the transaction would be properly
litigated in the foreign jurisdiction from the position
of plaintiffs in the Currie (para 19) action who had
done nothing to invite or invoke Illinois jurisdiction.
The court demanded that the procedures adopted
in the Illinois case be sufficiently attentive to the
rights and interests of the Canadian class members.
In this case, given the small stake of each individual
class member, principles of order and fairness could
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Class Actions
be satisfied if the interests of non-resident class
members were adequately represented in Illinois and
if it were clearly brought home to non-resident class
members that their rights could be affected in the
Illinois proceeding if they failed to take appropriate
steps to be removed from the Illinois proceeding.
The Court of Appeal recognized the small stake
of each individual in the Currie and Boland actions.
Significantly, the court noted that in some cases, the
nature of the rights and interests at stake would make
an opt-in requirement appropriate as a prerequisite
to recognition and enforcement (Currie, para 29).
The extent of review or oversight to be exercised
by the enforcing court is not clear. Enforcing courts
are almost always urged not to review an underlying
foreign money judgment. Canadian courts consider
the following factors in assessing the fairness of settlements of domestic class actions (Sauer, para 77):
• likelihood of recovery, or likelihood of
success;
• amount and nature of discovery, evidence or
investigation;
• settlement terms and conditions;
• recommendation
and
experience
of
counsel;
• future expense and likely duration of litigation and risk;
• recommendation of neutral parties, if any;
• number of objectors and nature of
objections;
• the presence of good faith, arm’s-length
bargaining and the absence of collusion;
• the degree and nature of communications by
counsel and the representative plaintiff with
class members during the litigation; and
• information conveying to the court the
dynamics of, and the positions taken by the
parties during the negotiation.
While Canadian courts may be prepared to assess
the fairness of foreign proceedings against standards
of an international class action invoking the assertion of jurisdiction against non-residents and not
against domestic requirements (Currie, para 42), it is
likely that the courts will develop and articulate some
standard of review.
International organizations are also struggling
with the issue. The International Bar Association
Task Force on International Procedures and Protocols for Collective Redress has released its Guidelines
for Recognizing and Enforcing Foreign Judgments for Collective Redress.
A close examination of the guidelines is beyond the
scope of this article, however, the task force recommends that the enforcing court not review the results
of the foreign court except in limited circumstances
including where the results achieved are “patently
inadequate.” The task force focuses on the requirements of natural justice and due process including
notice, the right to opt out and the right to be heard.
The efforts of the task force are welcome and it
is hoped that they will stimulate debate over the
preclusive effect of international class actions and
multi-jurisdictional class actions in Canada.
The task force is led by Chief Justice Warren
Winkler, the chief justice of Ontario and president of
the Court of Appeal for Ontario, who has produced
many of the important class action decisions in
Ontario and Canada. As a result, the guidelines and
the continuing work of the task force will be of interest to counsel following Canadian developments in
the enforcement of cross-border class actions.
Multi-Jurisdictional Class Actions
Uncertainty over the preclusive effect of international class action settlements explains the
proliferation of parallel class actions in Canada.
Meanwhile, the efficacy of multi-jurisdictional classes
in Canada is continuing to attract judicial attention.
The following discussion provides an overview of the
issues under consideration.
Several of the cases involve disputes between
competing class actions brought in different provinces.
Consequently, the intended class membership
overlaps because of the inclusion of extra provincial
members in one or more classes (Canadian provincial
statutes are divided between those that will permit
and include extra provincial members in the class
subject to a right to opt out of those that are silent
on the issue and those that will only include an extra
provincial member in the class if the class member
opts into the action). The development of a national
modus operandi for the recognition of provincial certification orders and multi-jurisdictional classes is
proving to be difficult.
Multi-jurisdictional classes have been certified in
Ontario for several years (Nantais v. Telectronics Proprietary [Canada] Ltd., [1995] 25 O.R. [3d] 331; leave to
appeal refused 25 OR [3d] 347 [Div. Ct.]; leave to
appeal denied [1996], 7 C.P.C. [4th] 206 [O.C.A.])
and since then in some other provinces. It must be
acknowledged that in the majority of cases, plaintiff
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Expert Witnesses
class counsel cooperate and do not compete to represent common claimants. In many instances, no party
challenges the efficacy of a multi-jurisdictional class.
Further, the courts have often supported efforts to
harmonize proceedings.
In Boehringer Ingelheim (Canada) Ltd. v. Englund, the
Saskatchewan Court of Appeal was faced with parallel
proceedings commenced by the same representative
plaintiffs in Ontario and Saskatchewan. There was
no suggestion that multiple claims served any legitimate interest of the plaintiffs. The Court of Appeal
conditionally stayed the Saskatchewan proceeding
and offered to lift the stay if the Ontario action were
to be discontinued. The plaintiffs in the Ontario
action later successfully obtained the approval of the
Ontario court for the discontinuance of the Ontario
action (Sollen v. Pfizer Canada Inc., [2008] CanLII
8618 [ONSC]; the appeal was dismissed in Sollen v.
Boehringer Ingelheim [Canada] Ltd., [2008] ONCA 803
CanLII).
Considerably less coordination has been achieved
in competing class actions in Ontario and Saskatchewan arising from VIOXX claims. Competing claims
were first brought in Ontario. The Ontario court
conducted a carriage hearing in February 2006. The
action of the Setterington et al v. Merck Frosst Canada
Ltd. et al plaintiffs was permitted to continue and the
action commenced by plaintiff Wuttunee was stayed.
Ultimately, the Wuttunee plaintiffs obtained a certification order in Saskatchewan for a plaintiff class
comprised of resident and non-resident class members
on an opt-out basis. The Ontario-intended class and
the Saskatchewan-certified class overlapped.
Counsel for the defendant Merck moved to stay the
Ontario proceeding, but the Ontario court refused
to order the stay notwithstanding the competing
Saskatchewan action. The decision was grounded on
the fact that a carriage motion was fully argued in
Ontario and decided two and half years prior and the
Ontario action had progressed to the certification
hearing stage.
The Ontario court declared that the continuation
of the two actions in this case was unfortunate. The
court noted that if decisions of provincial superior
courts on carriage motions are not to be respected
throughout Canada, this makes more urgent the need
for an agreement or protocol among the superior
courts that will provide for nationally accepted
carriage motions and a determination of the jurisdiction in which such motions will be heard.
The Divisional Court dismissed Merck’s appeal of
this decision on February 13, 2009. Merck argued that
simultaneous competing class actions certified in two
different provinces involving the same plaintiff class
and substantially the same claims would create chaos,
confusion, uncertainty and the possibility of inconsistent verdicts. The court found the consequences
to be exaggerated and accepted that the two actions
are unfortunate, but the problems are solvable with
cooperation, communication and direction from the
courts.
In the latest development in March 2009, the
Saskatchewan Court of Appeal quashed the order
certifying the Saskatchewan class action and
terminated (for at least the time being) one of the
competing actions.
The Court of Appeal declined to consider whether
the Saskatchewan court erred in certifying the action
as a multi-jurisdictional class action. The court did
observe the potential for chaos and confusion if some
Canadian residents were presumptively members of
two class actions. It is not yet known if this is the final
development on this issue in this action.
One of the most active class action jurisdictions
in Canada is the province of Québec. The issue of
whether multi-jurisdiction class actions certified in
other jurisdictions may be received in Québec is not yet
settled. Recent cases suggest that, while multi-jurisdictional classes may be viable in certain circumstances,
Québec courts will be hesitant to receive and enforce
such judgments on the basis of comity when the
foreign jurisdiction can be perceived to have no real
and substantial connection with Québec residents.
Moreover, deficient notices to members and other
procedural fairness issues may prevent a national
settlement from being accepted by Québec courts.
In Hocking v. Haziza, a majority of the Court of
Appeal upheld the Superior Court decision to deny
a joint motion by the plaintiff and the respondent for
the enforcement of a multi-jurisdictional class action
certification judgment (for settlement purposes)
rendered in Ontario. Hocking had launched a
purported national class action lawsuit in Ontario
against HSBC Bank Canada on behalf of all Canadian
persons having made mortgage prepayments. When a
settlement agreement was reached between Hocking
and HSBC, the Ontario courts approved the settlement, purporting to bind all Canadian residents,
including Québec residents.
Haziza, whose intended class action in the Québec
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Class Actions
courts on behalf of Québec residents for essentially
the same claim had not yet been authorized, had
been denied leave to intervene in the Ontario class
action settlement approval hearing. Moreover, notices
The disharmony
in Canada has
attracted the
attention of the
Uniform Law
Conference of
Canada.
ings in Québec, the Ontario judge refused to decline
jurisdiction over the Québec residents. Meanwhile,
the Québec class action was following its course.
The Québec Superior Court authorized the class
action to proceed as such on behalf of the Québec
class after the national settlement agreement had
already been approved in Ontario. Québec residents
were therefore faced with: (a) a national settlement
agreement that purported to bind them; and (b) an
authorized class action following its normal course
in Québec.
to advise members of the settlement agreement were
not widely disseminated in Québec. The Québec
Superior Court and the majority of the Québec
Court of Appeal decided the notice program was in
breach of fundamental principles of the Civil Code of
Québec, which deals with the enforcement of foreign
judgments.
As in the Hocking case, dissemination and content
of the notices in Lépine was an issue for the Québec
courts asked to enforce the Ontario judgment
approving the settlement. The Ontario settlement
notice did not clearly state whether and to what
extent the settlement applied to Québec residents,
who had already received a notice advising them
that the parallel class action had been authorized
in Québec. The notices were therefore deemed by
the Supreme Court of Canada to be in breach of the
fundamental principles of procedure. The Supreme
Court also agreed with the Québec Court of Appeal’s
ruling on the issue of lis pendens in holding that
the Ontario certification and settlement approval
judgment could not be enforced in Québec because
the application for authorization of a class action
filed in that jurisdiction pre-dated the Ontario
proceeding and therefore precluded judicial recognition of the latter under Québec rules governing
the enforcement of external judgments. Finally,
Canada’s highest court also harmonized civil law
with common law by eliminating forum non conveniens as part of the jurisdiction analysis in enforcing
external judgments.
A national settlement agreement entered into in
Canada Post Corporation v. Michel Lépine (2009 SCC
16) was similarly denied enforcement in Québec.
The Québec Superior Court decision to deny
enforcement was upheld by the Québec Court of
Appeal. The Supreme Court of Canada also upheld
the latter decision in a much anticipated judgment
released on April 2, 2009.
While Québec courts are currently struggling
with the issue of enforcement of multi-jurisdictional
class action settlements approved in other provinces,
the Québec Superior Court has recently authorized
a multi-jurisdictional class action on behalf of all
Canadian residents who consumed the injectable
contraceptive Depo-Provera, in the case of Brito v.
Pfizer Canada Inc.
In Lépine, parallel intended class action proceedings had been instituted in Ontario, Québec and
British Columbia. The class action instituted
in Ontario was national but excluded Québec
residents, whereas the British Columbia and Québec
proposed class actions had been instituted on behalf
of residents of those respective provinces only. A
national settlement agreement was approved in
Ontario. Although advised of the pending proceed-
The respondents argued, inter alia, that the
provisions governing class actions in Québec could
not have extra-territorial application and that the
common issues asserted by the plaintiff could not
constitute the basis for a real and substantial connection between the non-resident class members and
the Québec courts. They also argued that members
of the class residing in other provinces could not
be bound by a final judgment without having been
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Expert Witnesses
properly informed of the proceedings, as was the
case in Hocking and Lépine.
in the recent past. This brings uncertainty to crossborder class actions.
The court favored the avoidance of multiple
proceedings in other jurisdictions. Moreover, the
court concluded that since Pfizer Canada Inc.’s
principal place of business was in Québec and the
allegations tied the cause of action to that province,
the courts of Québec had jurisdiction over the
company. In addition, the federal Competition Act,
invoked in support of the class action, applies
throughout Canada. In regards to the issue of
whether the members of the plaintiff class would be
sufficiently informed of the class proceedings, the
court concluded that this was not a bar to authorization and that another hearing would be conducted
to determine the appropriate means of disseminating national notices.
The determination of the territorial scope of
the enforcement of a class action judgement or
settlement against absent claimants is complicated and consideration must be given to the
location of claimants and witnesses, any differences in substantive rights or remedies between
different provinces (particularly between common
law provinces and Québec), as well as to the rules
of jurisdiction identifying real and substantial
connections between the dispute and the forum,
and the adequacy of representation and procedural
fairness accorded to absent claimants. The degree
of scrutiny of the enforcing court into the reasonableness of a judgment of a foreign court be it an
award or a settlement approval, whether judgment
or settlement, remains a matter of debate. It is likely
that the courts will remain sensitive to the interests
of class members residing in the enforcing court’s
jurisdiction, but represented in a different province
or country (conventional rules of practice require
court approval of settlements of claims of persons
under disability, including infants). It is anticipated that the current uncertainty will exist for a
considerable period of time until protocols governing multi-jurisdictional classes and international
classes are developed.
The disharmony in Canada has attracted the attention of the Uniform Law Conference of Canada. It
established a Committee on National Class Actions
and Related Interjurisdictional Issues in 2004. The
conference has produced two reports. In the initial
report, the conference recommended that the first
court to certify should take jurisdiction over the
largest appropriate class. It would then fall to plaintiff counsel bringing a competing class action in
any other jurisdiction to persuade the court in the
second jurisdiction that some members of the plaintiff class would be better served by permitting the
second class action to proceed.
The conference recommended that class proceedings legislation in all Canadian jurisdictions should
require any court to determine whether a related class
proceeding is the most suitable forum for resolution
of the claims of all or some of the class members,
based on the interests of all the parties, the ends
of justice, the risk of irreconcilable judgments and
judicial economy by considering four enumerated
factors, including the basis of alleged liability, the
state of proceedings, the location of class members
and the location of evidence, including witnesses.
The conference represents another voice urging
coordination and the efficacy of multi-jurisdictional
classes, but without success at this date.
Conclusion
The foregoing discussion illustrates the difficulties which have arisen in the coordination of class
action proceedings in different provinces of Canada
The Supreme Court of Canada noted in Lépine,
cited above, that decisions from equal yet different
jurisdictions within the Canadian federal system
can sometimes cause friction. The Supreme Court
of Canada has called on the legislatures of the
provinces to address a framework for national class
actions.
This uncertainty puts greater responsibility on
counsel to determine how proceedings may be coordinated and harmonized to obtain the best result for
their client’s interests. There are greater chances for
coordination of cross-border class actions in cases
where plaintiffs’ counsel in the United States and
Canada cooperate and counsel are not competing to
represent overlapping classes. As a practical matter,
opposing counsel often cooperate on overlapping
matters. Production and discovery in Canadian class
actions are often preceded by production and depositions in the actions in the United States. The courts
should encourage and promote this coordination
while the courts cannot coordinate jurisdictions for
certification and trial.
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Class Actions
Timothy O. Buckley, Borden Ladner Gervais LLP
Tel: (416) 367-6169 • Fax: (416) 361-7062 • E-mail: [email protected]
P
artner in BLG’s Toronto office and national leader of the Class Actions Group. Buckley
gained experience in the defence of mass tort claims prior to and after the introduction of
class proceedings legislation and practices commercial and product liability litigation, including class actions. He has an LLB (1980) and a Masters of International Law degree from The
Australian National University and a Bachelor of Applied Sciences and Engineering degree.
He was called to the Ontario Bar in 1983.
Robert E. Charbonneau, Borden Ladner Gervais LLP
Tel: (514) 954-2518 • Fax: (514) 954-1905 • E-mail: [email protected]
P
artner in BLG’s Montréal office. Practice is focused primarily on class actions, insurance law, professional liability of insurance brokers, product liability and civil liability
in aviation matters. Recognized in Chambers Global as one of the world’s leading lawyers for
Business (dispute resolution/litigation) and listed in The Best Lawyers in Canada as a leading
“bet-the-company” litigator. He was admitted to the Québec Bar in 1975 and is a graduate of
the McGill University Law School.
Julia Mercier, Borden Ladner Gervais LLP
Tel: (514) 954-3148 • Fax: (514) 954-1905 • E-mail: [email protected]
A
ssociate in BLG’s Montréal office. Member of the Commercial Litigation Group, and
practices primarily in the areas of class actions, product liability and private international
law. She currently advises clients involved in major class actions involving multiple defendants,
cross-border litigation and private international law issues. She was called to the Québec Bar
in 2005 and obtained her Bachelor of Law at the Université de Montréal.
Reprinted with permission from the July 2009 Lexpert Guide to the Leading US/Canada
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