Law360 Canada ( November 25, 2025, 10:26 AM EST) -- Appeal by appellant from an order declaring him in civil contempt. The appellant failed to provide adequate responses to several undertakings he was ordered to satisfy. The parties were engaged in litigation since 2012 after being involved in real estate development projects in Alberta and the United States. The respondent sued the appellant and others advancing several causes of action including breach of contract, fraudulent misrepresentation and conspiracy. In June 2016, the case management judge issued an order directing the appellant to provide answers to undertakings. The respondent filed several applications seeking orders for further and better answers, and to find the appellant in contempt. This prompted the chambers judge to issue an order requiring the appellant to respond to 40 outstanding undertakings within 45 days and providing specific directions to the appellant. The respondent filed another contempt application. The chambers judge issued his reasons and found the appellant in contempt in respect of 32 of 35 of the undertakings (Decision). The appellant maintained that the chambers judge displayed bias, improperly directed the appellant to provide affidavit evidence and then used this evidence against him, and erroneously applied the test for civil contempt....