In Ontario v. Madan (Ont CA, 2023) the Court of Appeal, in a fraud lawsuit by the province, noted statutory remedies - including Mareva injunction and preservation orders - under the Civil Remedies Act:
 In October 2020, Ontario obtained an ex parte Mareva injunction and a preservation order under the Civil Remedies Act, 2001, S.O. 2001, c. 28. The appellants subsequently consented to the continuation of the Mareva injunction and the preservation order.
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