Toronto Estate Law Blog

Modern-day Grave Robbing?

Hull & Hull LLP — Fri, 10 Jul 2009 00:19:14 -0500

CNN recently reported disturbing events, whereby employees at a historic cemetery near Chicago allegedly dug up more than 300 graves as part of a conspiracy to resell burial plots to unsuspecting buyers.

Reportedly, at least four people are in custody facing a slew of felony charges. Additionally, investigators are in the process of attempting to determine the scope of the scheme. It may not be an easy task since, among other things, it is possible that the employees doctored records to conceal the scheme. They are expected to use thermal imaging to assist their efforts, and have brought in forensic scientists to help.

While most of the excavations reportedly occurred in back lots, where the plots were older and not frequently visited, they are not certain of this. Other plots may have been disturbed as well.

Investigators are faced with the unenviable task of trying to find the families of those whose graves were disinterred, as well as those people who unknowingly purchased occupied plots.

A sad day indeed….

Natalia Angelini

Taking Evidence Out of Court In Lieu of Calling the Witness at Trial

Hull & Hull LLP — Thu, 09 Jul 2009 00:01:35 -0500

Given the nature of estate litigation, a party to the dispute, and/or a witness that is to testify at trial, are at times elderly, in poor health, incapable of testifying or out of the jurisdiction, such that it is appropriate for their evidence to be given out of court in advance of the trial date. Rule 36 of the Rules of Civil Procedure regulates taking of evidence before trial.

A person may be examined under this Rule either by consent of the parties or with leave of the court. The court is to take into account several factors when determining whether to grant leave to order an examination before trial, which are particularized in Rule 36. These include the convenience of the witness and saving of costs. This permits the court to take a more broad approach, since previously these orders were limited to situations where it was established that the witness will likely be out of the jurisdiction or incapable of testifying.

Moreover, previously, leave of the court was necessary before the examination of a witness could be used at trial. Now, the transcript or videotape of the examination of a witness who is not a party may be used “unless the court orders otherwise”, and the witness shall not be called to give evidence at trial except with leave of the court. In contrast, the transcript or videotape of the examination of a witness who is a party may not be used except with leave of the court or the agreement of the parties.

While it seems to me that live testimony will likely have more impact then a transcript or videotape, if the circumstances warrant it, this is a handy tool to avoid difficulties and complications in attempting to get witnesses and/or parties on the stand when the trial date arrives, and ensures the evidence is preserved and gets before the court.

Have a great day,

Natalia Angelini

Parties Under Disability - Hull on Estates #170

Hull & Hull LLP — Wed, 08 Jul 2009 17:40:10 -0500

This week on Hull on Estate and Succession Planning Natalia Angelini and Bianca La Neve discuss parties under disability. They look into how they are represented in proceedings and who has the authority to do so.

If you have any comments, send us an email at hullandhull@gmail.com or leave a comment on our blog.

Planning Ahead - Transferring the Family Cottage - Hull on Estate and Succession Planning #171

Hull & Hull LLP — Wed, 08 Jul 2009 16:42:58 -0500

Listen to Planning Ahead - Transferring the Family Cottage

This week on Hull on Estate and Succession Planning Ian and Suzana look at the more complex solutions to the transfer of a cottage. The discuss the inter vivos transfer - putting the cottage in trust for your children while you are living.

If you have any comments, send us an email at hullandhull@gmail.com or leave a comment on our blog.

Cost Awards - Not What They Used to Be

Hull & Hull LLP — Wed, 08 Jul 2009 00:04:51 -0500

As noted in one of my earlier blogs, gone are the days where estate litigants almost automatically were awarded their costs out of the estate. The trend in recent years has adopted elements of the loser- pays philosophy, which has long been applied to other types of litigation.

Moreover, parties in estate matters who conduct themselves in such a manner that serves to protract and unnecessarily increase the costs of litigation can more and more often find themselves penalized with a cost award.

This trend is no more clearly seen than in Teffer v. Schaefers, a recent decision of the Ontario Superior Court of Justice, where an estate trustee was Ordered to personally pay more than half of the legal costs awarded to the various other parties due to his conduct in the litigation.

That said, less than 25% of the aggregate legal costs sought were actually awarded (although I understand further submissions are being made). This result is indicative of another noteworthy trend that we are seeing in estate matters. That is, judges are increasingly exercising their discretion to ensure cost awards are subject to the overriding principle of fairness and reasonableness in light of all the circumstances of each particular case, as well as proportionate to the amount at issue (in addition to being reflective of the factors set out in Rule 57.01(1) of the Rules of Civil Procedure).

This decision should serve as a caution to anyone involved in estate litigation – costs (even to the victor) are not guaranteed!

Have a great day,

Natalia Angelini

Parties Under Disability - Who Can Advance Their Interests and How Does One Get The Authority To Do So?

Hull & Hull LLP — Tue, 07 Jul 2009 00:07:41 -0500

In estate litigation it is not uncommon for one or more disputing parties to be under disability. Unless the court or a statute provide otherwise, a party under disability must be represented by a litigation guardian (see Rule 7 of the Rules of Civil Procedure, which regulates proceedings by or against parties under disability).

Someone can act as the litigation guardian for a plaintiff (or applicant) by filing an affidavit with the court, the required contents of which are set out in Rule 7.

In the case of a defendant (or respondent) who is a minor, the Children’s Lawyer shall act as the litigation guardian, unless the court orders otherwise.

In contrast, in the case of a defendant who is an adult, aside for a few exceptions set out in the Rule, no one can act as a litigation guardian until appointed by the court. The evidence that must be filed in support of the motion for such appointment is also particularized in the Rule.

Some other noteworthy provisions in Rule 7 are:

· a litigation guardian other than the Children’s Lawyer or the Public Guardian and Trustee must be represented by a lawyer;

· a litigation guardian shall diligently attend to the interests of the person under disability and take all steps necessary for the protection of those interests, including the commencement and conduct of a counterclaim, crossclaim or third party claim;

· where it appears to the court that a litigation guardian is not acting in the best interests of the party under disability, the court may substitute the Children’s Lawyer, the Public Guardian and Trustee or any other person as litigation guardian; and

· no settlement of a claim made by or against a person under disability, whether or not a proceeding has been commenced in respect of the claim, is binding on the person without the approval of a judge.

Have a great day,

Natalia Angelini

Testamentary Custody and Guardianship

Hull & Hull LLP — Mon, 06 Jul 2009 00:35:47 -0500

The sudden death of Michael Jackson has sent a shock-wave of sadness across the globe. I expect it will be some time before you can tune in to various media without seeing coverage on it.

I find myself drawn in to the discussion, which one of my colleagues also blogged on last week. His commentary focused on the expected complex administration of Jackson’s estate, given both his sizeable assets and debts. This blog focuses on one aspect of the human element of the tragedy, sparked by Jackson’s Will.

As noted in a recent New York Times Article, in his Will Diana Ross is appointed as the guardian for Jackson’s children if his mother is no longer willing or able to fulfill that role.

In Ontario, a custody or guardianship appointment by Will is not determinative of the issue. It only has a temporary effect, in that any appointment for custody or guardianship expires ninety-days after such appointment becomes effective (i.e. ninety-days from the date of death in this case) (see section 61(7) of the Children’s Law Reform Act).

However, if the appointee applies to the court for custody or guardianship within the ninety-day period, the appointment expires when the application is disposed of. While each case is usually fact-specific, I would expect that a testator’s wishes set out in his/her Will is a factor a court would give significant weight to when considering such an application.

In Jackson’s case this issue is already a live one, with potentially several people vying for custody and/or guardianship. It will be interesting to see who ends up being the primary caregiver(s) of his young children.

Have a great day,

Natalia Angelini

Adult Children Making Gains

Hull & Hull LLP — Thu, 02 Jul 2009 23:30:34 -0500

My colleague Natalia Angelini blogged on February 18 of this year about the increasing possibility that independent, adult children may be entitled to dependant support.

A 2009 Ontario Bar Association paper by Susan Woodley concluded that moral obligations of deceased parents in Ontario may require them to provide proper and adequate support to their children, spouse and dependants.

While the legislation in British Columbia clearly distinguishes any case from that province, a consideration of a recent case on point illustrates the roots of this evolving trend.

In Sikora v. Sikora Estate 2009 BCSC 195, two of four adult sons of the testator brought an action under B.C.'s Wills Variation Act. The Deceased had one child by his first marriage, three children with a subsequent common-law spouse, and at his death he was married to the defendant, San Meei Sikora. The Deceased’s residue to be divided amongst three sons equalled just over $11,500.

The two plaintiff brothers maintained contact with their father despite a difficult childhood. Each plaintiff provided evidence of respective incomes of about $90,000 and $35,000 and described their relationships with their father whom they assisted in his business and investment properties over the years. The Deceased’s wife’s responses created some credibility problems for her.

Justice Cullen reviewed the case law from the Supreme Court, Tataryn v. Tataryn Estate and a B.C. case, Clucas v. Clucas Estate (1999), 25 ETR (2d) 175 (BCSC) that summarizes the principles of the Wills Variation Act.

In Sikora, the Deceased’s wife accumulated her own assets while the Deceased did not. The plaintiffs showed that despite their independence their father had a moral obligation towards them. The residue of the Deceased’s estate diminished in a manner that favoured his surviving wife and his moral obligation to his spouse was less firmly established than in other cases.

The Deceased used his money to purchase the matrimonial home, allowing the defendant to invest her money and increase her own assets. The plaintiffs succeeded and were therefore registered as tenants in common on a property with a life interest to the defendant.

Thank you for reading this week. Enjoy your weekend.

Jonathan

News Stories That Impact Estate Litigation - Hull on Estate and Succession Planning #169

Hull & Hull LLP — Thu, 02 Jul 2009 18:32:41 -0500

Listen to News Stories That Impact Estate Litigation

This week on Hull on Estates Jonathan Morse and David Smith discuss some big stories that have occurred in the news lately that have potential impact on those who practice estate litigation. They take a look at the death of Michael Jackson and the decision made by the courts in regards to the sentencing of Bernard Madoff.

If you have any comments, send us an email at hull.lawyers@gmail.com or leave a comment on our blog.

The Family Property - Part 2 - Hull on Estate and Succession Planning #170

Hull & Hull LLP — Thu, 02 Jul 2009 18:26:20 -0500

Listen to The Family Property - Part 2

This week on Hull on Estate and Succession Planning Ian and Suzana continue their discussion on the family property. They look into two simple options when choosing to manage the transfer of wealth of a cottage - gifting it during your lifetime and selling the property.

If you have any comments, send us an email at hullandhull@gmail.com or leave a comment on our blog.

Another Reason to Respect Your Elders

Hull & Hull LLP — Wed, 01 Jul 2009 22:32:00 -0500

They bound me with masking tape until I looked like a mummy. It took them
quite a while because they ran out of breath. When they loaded me into the
car I thought I was a dead man.
- James Arnburn, financial adviser and alleged kidnapping victim

Having lost their savings to Florida’s boom-and-bust property market, and apparently sporting one heckuva grudge, Roland and Willy, ages 74 and 60, respectively, reportedly clobbered their financial adviser, James Arnburn, with a walker, bound him with duct tape, then took him for a long drive in the trunk of their Audi. After arriving at Roland’s home a mere 300 miles away, they were joined by retired doctors Gerhard and Iris, ages 63 and 66. The foursome proceeded to hold Mr. Arnburn captive in an unheated cellar for four days, during which time they allegedly burned him with cigarettes, beat him with a chair leg, and even threatened him with the Russian mafia. Armed commandos were eventually scrambled, the house was stormed and Mr. Arnburn was rescued from his ordeal.

According to the Daily Telegraph, this is only the latest example of what is being referred to as ‘silver crime’ – ‘the violent backlash of pensioners who feel cheated by the world.’ To wit, the Times Online reported that over the course of nine years, a group of pensioners dubbed the Grandpa Gang and 'armed' with carrots in their pockets, robbed 14 banks across Germany in an attempt to boost their retirement savings and alleviate their disgust over the size of bankers’ bonuses. The trio won’t be back at the bridge table for about ten years, possibly less for good behaviour.

Jennifer Hartman, Guest Blogger

Accessing National Memories

Hull & Hull LLP — Mon, 29 Jun 2009 22:30:00 -0500

Tomorrow is July 1^st. It makes me think of Hatley, a small village in Quebec’s Eastern Townships and its annual Canada Day Celebration. (My wife grew up nearby.) Across Canada, flags fly high and memories abound.

If you will allow this segue, memories are often a significant part of estates that are easily overlooked. When an estate arises, we often focus on assets without putting our mind to the deceased’s legacy. For many of us, our papers and personal files do not amount to much. But it’s a different story for politicians.

An interesting paper from the Faculty of Information Quarterly at the University of Toronto compares the treatment of Presidents’ papers versus Prime Ministers’ papers. The retention of U.S. papers seems to be more statute driven, although presidential Executive Order can govern the ultimate treatment of documents.

Apparently, on his first day on the job, President Obama overturned President Bush’s order that had limited access to presidential papers.

In Canada, Prime Ministers’ papers fall into two categories: government/institutional records and personal/political records. Former Prime Ministers receive tax credits for the value of the personal papers they donate to Library and Archives Canada. That value is not disclosed.

Similarly, in the U.S., some financial incentives exist for Presidents: in 2000, the Justice Department paid the Nixon estate $18 million to compensate for records seized in 1974.

In both cases, restrictions regarding the release of certain documents might apply. For example, apparently here in Canada, for 2.5 million records in the National Archives, one must write to Mr. Mulroney directly for permission.

Have a safe, relaxing Canada Day.

Jonathan

The Death of a Legend: Michael Jackson leaves loose ends

Hull & Hull LLP — Sun, 28 Jun 2009 23:30:00 -0500

Many people, including myself, paused on learning of Michael Jackson’s death. While I have not searched out his music for several years, his death marks the end of an era.

Michael Jackson’s music is part of my memory of growing up. I attended his concert in October 1984 at the Canadian National Exhibition in Toronto.

Of course, in my role as an estate litigator, other thoughts also come to mind. Namely, what issues will arise in untangling Michael Jackson’s estate?

Some of these issues are addressed in a New York Times article. One executive describes the singer's estate as a "mess". There are clearly valuable assets, including a 50 percent share of Sony/ATV Music Publishing which owns the rights to more than 200 Beatles songs; this asset alone may be worth more than $500 million. Apparently these shares were not owned directly by the pop star, but rather by a trust controlled by his mother. The shares therefore may not fall to Michael Jackson's estate but they would be part of his legacy.

The estate has debts too: Neverland cost many millions of dollars to operate annually and in recent years there was a $24.5 million debt against the property. Some commentators estimate Michael Jackson’s overall debt to be $400 million.

All of these issues – from copyright and real estate assets to Michael Jackson's personal and business loans – will take many months, if not years, to sort out.

There were recent plans for a 50-concert comeback in London, England. Apparently fans had paid $90 million which will have to reimbursed and the concert preparations included payments for renovations to the venue as well as advance payments to Michael Jackson.

As the administration of Michael Jackson’s estate unfolds, I suspect there may be more related topics to be covered in our blog.

Of course, for us regular folks, estate issues that we encounter in our own lives will be simple in comparison to the challenges faced by the Jackson family. But there are some lessons: careful management of one’s affairs and good planning will lessen the load on named executors and estate trustees.

Enjoy your Monday.

Jonathan

The Contested Passing of Accounts - Part 3 of 3

Hull & Hull LLP — Fri, 26 Jun 2009 00:17:40 -0500

Today’s blog is the last in my series this week addressing certain aspects of preparation for trial in a contested passing of accounts. The items discussed this week were certainly not meant to be, nor were they, exhaustive. Preparation necessary for a hearing/trial with narrow issues, few documents, few evidentiary concerns and an uncomplicated Estate will obviously be different than a case with numerous issues, voluminous documents, evidentiary issues and a complicated administration. The critical aspect of trial preparation is that it begins at the beginning of a case; not literally, but certainly in the sense of being mindful at pre-trial stages of the evidentiary considerations and how the evidence is to be marshalled and presented.

Aside from ensuring that you have appropriate resource materials at the trial (such as texts dealing with the rules of evidence, the Rules of Civil Procedure, Probate Practice etc.), it is important to have prepared your opening and closing statements (to the extent possible), have prepared the necessary law regarding the substantive issues in dispute (casebook, factum), have addressed costs submissions (organizing offers to settle, preparing a Bill of Costs etc.), and have a trial binder with you at trial for your own use.

A trial binder typically contains the pertinent materials that you would like to have at your fingertips during the trial (ie. pleadings, orders, witness lists, witness summaries, answers to undertakings, listing of the types of evidence, objections, offers to settle etc.). The trial binder will allow you to have quick access to information that you might only have a few minutes or less to locate and quickly review.

While most contested passings settle at a pre-trial stage, if a trial is necessary, success may hinge on the preparedness of the parties.

Thanks for reading this week.

Have a great weekend.

Craig

The Contested Passing of Accounts (Continued)

Hull & Hull LLP — Thu, 25 Jun 2009 00:49:19 -0500

Today’s blog is a continuation of my blogs this week addressing some aspects of preparation for a trial in a contested passing. I briefly touch upon transcripts, the Request to Admit and Witnesses today.

It is important in preparing for trial to review the transcripts of the examinations conducted to assist counsel with locating evidence in the transcripts during trial, including admissions and/or inconsistent statements made by a witness at trial, to address the completeness of questions on the examinations, and whether additional discovery is needed before trial.

If a damages brief is to be provided by the opposing party as a result of an undertaking at examinations or otherwise, ensure that it has been provided.

A party may also, further to Rule 51.02 of the Rules of Civil Procedure, at any time, by serving a Request to Admit, request any other party to admit, for the purposes of the proceeding only, the truth of a fact or the authenticity of a document. A copy of any document mentioned in the Request to Admit shall, where practicable be served with the request (unless a copy is already in the possession of the other party).

The opposing party must respond to the Request to Admit within 20 days, failing which the opposing party will be deemed to admit the truth of the facts asserted in the Request to Admit or the authenticity of the documents referred to in the Request to Admit. As such, the Request to Admit should be served at least 20 days before the commencement of the trial, and quite some time before that, if possible, so that counsel will know what facts need not be proved or the authenticity of documents that will not need to be proved.

There may be cost consequences if a party refuses to admit the truth of a fact or authenticate documents which are proven or authenticated during the trial.

Requests to Admit may be effective to: (i) reduce the facts in dispute, (ii) reduce the number of witnesses to be called and/or the examination of a witness, (iii) minimize the costs and length of the trial, and (iv) avoid having to authenticate documents.

With respect to witnesses, amongst other things, it is helpful to make a witness list of anticipated witnesses for each of the parties, prepare a chart of the issues/documents to be proved by each witness and identify and consider the concerns, evidentiary or not, with the evidence and documents to be dealt with by each witness. If the witnesses are experts, Rule 53 of the Rules of Civil Procedure is applicable. Summons to Witness need to be considered (Rule 53.04) as well as whether an Order excluding witnesses is necessary (Rule 52.06).

Thanks for reading.

Craig

The Contested Passing of Accounts - Part 1 of 3

Hull & Hull LLP — Wed, 24 Jun 2009 01:14:03 -0500

My blogs over the next three days will relate to certain aspects of preparation for the hearing of a contested passing of accounts. Today’s blog will touch upon the parties, the scheduling of the hearing, and the preparation of documents/productions for trial.

The issue of whether all of the parties who ought to be involved in the passing are involved, and, if so, whether any of the parties who do not have representation need representation, must be considered. In considering who the appropriate parties are, or should be, the following questions might be asked: Are there self-represented parties? Have they been notified of all matters related to the proceeding? Has any party filed a Notice of No Objection to the accounts? Has anyone filed a Statement of Submission of Rights (if so, have they been served by the applicant/plaintff with written notice of the time and place of the hearing)? Is a minor involved (Rule 7.03(2), The Office of the Children’s Lawyer)? Is there an adult party who is disabled (Rule 7, The Office of the Public Guardian and Trustee)? Is a representation Order necessary (Rule 10)?

Regarding the scheduling of the hearing, an order of the Court for directions, or otherwise, at any pre-trial stage, or at the pre-trial conference might address same. It may be that the date of the trial, fixed in its length, is to be fixed by the Registrar on a date mutually convenient to the parties. If, on the other hand, the proceeding is to be set down for trial, Rule 48.01 of the Rules of Civil Procedure allows for the proceeding to be set down for trial after the close of pleadings and when a party is ready for trial. In any case, inquiries should be made with the Court office about where the trial is to take place to determine what, if any, forms need to be filed with the Court to confirm that the trial is to proceed.

Regarding the preparation of documents/productions for trial, it is critical that the documents in respect of the proceeding be organized prior to trial. If the documents necessary for the trial are not in counsel’s possession when preparing for trial, for whatever reason, they should be obtained prior to trial. Such documents include, but are not limited to, all pleadings, the estate accounts, certificate of appointment, prior Judgments for passing of accounts, all Orders regarding the passing of accounts, all Notices of Objections (and withdrawals), Statements of Submission of Rights, Consents/Releases of any party, Affidavits of Service, and the documents exchanged between the parties as a result of the Rules of Civil Procedure, any agreement of the parties, and/or Court Order.

Issues of privilege regarding the documents should also be dealt with prior to trial.

Thanks for reading.

Craig

Taking Evidence Before Trial - Hull on Estates #168

Hull & Hull LLP — Tue, 23 Jun 2009 11:29:22 -0500

Listen to Taking Evidence Before Trial

This week on Hull on Estates Bianca La Neve and Natalia Angelini discuss taking evidence before trial. They talk about the procedure for witnesses who may not be available at trial, which involves preserving their evidence beforehand so it is available prior to the trial.

If you have any comments, send us an email at hull.lawyers@gmail.com or leave a comment on our blog.

OBA Trusts and Estates Section Executive

Hull & Hull LLP — Tue, 23 Jun 2009 09:13:15 -0500

In yesterday’s blog, I mentioned that the election of the Ontario Bar Association (OBA), Trusts and Estates Section Executive for the year 2009-2010 was confirmed at the Section’s year end dinner on May 28, 2009.

Suzana Popovic-Montag is the incoming Chair of the Executive and I happen to be the incoming

Vice-Chair. The balance of the slate is as follows:

Past-Chair: Kimberly Whaley

Secretary: Ed Esposto

Members-at-Large: Ann Elise Alexander, Clare Burns, Robert Coates, Vincent De Angelis, Shael Eisen, Jan Goddard, Eric Hoffstein, Danielle Joel, Sean Lawler, Mitchell Leitman, Jane Martin, Deborah Petch, Joanna Ringrose, Liza Sheard, Susan Stamm, Dina Stigas, Sender Tator, Ed Upenieks, Laura West and Melanie Yach.

I look forward to again working on the Executive and having a successful year.

Before turning the page on this past year, though, I would like to sincerely thank Kimberly Whaley for all of her efforts, hard work and counsel as the Chair of the Executive.

Have a nice day.

Craig

OBA Trusts and Estates Section Year End Dinner

Hull & Hull LLP — Mon, 22 Jun 2009 00:07:44 -0500

The Ontario Bar Association (OBA), Trusts and Estates Section, year end dinner was held on May 28, 2008 at the Gardiner Museum in Toronto.

Kimberly Whaley, the Chair of the Section for the past year, brought the past year to a close and the election of the OBA, Trusts and Estates Section Executive for the 2009/2010 year, was confirmed.

The Section also paid tribute to this year’s recipient of the Award for Excellence in Trusts and Estates, Timothy Youdan.

The Award for Excellence was created to recognize exceptional contributions and achievements by members of the OBA to the area of trusts and estates. The criteria for the award is demonstrated leadership in the trusts and estates bar through knowledge, experience, skill, commitment, passion and strength of character, plus all or some of the following:

· academic excellence through teaching at the Bar Admission Course, lecturing at a law school, participating in Continuing Legal Education and/or academic writing;

· participation in the OBA Trusts and Estates Section Executive or the Law Society of Upper Canada on wills, trusts and estate matters; and

· contribution to the development of wills, trusts and estate law.

In addition to the Award for Excellence, C. David Freedman was presented with the Widdifield Award and Kimberly Whaley with the Hoffstein Book Prize.

Congrats to Tim, David and Kim. The venue, dinner and evening were all quite enjoyable.

Thanks for reading.

Craig

This Blog Contains a Secret to Longer Life

Hull & Hull LLP — Fri, 19 Jun 2009 04:00:00 -0500

Actually, reading this blog really will help you live longer. One secret to living longer is to have a "higher purpose", according to researchers at the Rush Alzheimer's Disease Center (which is part of the Rush University Medical Center in Chicago). Patricia Boyle, Ph.D. states in the news release announcing the study:

"The finding that purpose in life is related to longevity in older persons suggests that aspects of human flourishing—particularly the tendency to derive meaning from life's experiences and possess a sense of intentionality and goal-directedness—contribute to successful aging,".

The study found a correlation between longevity and participant's level of agreement with 3 particular statements in a "Purpose of Life" questionnaire:

“I sometimes feel as if I’ve done all there is to do in life;”
“I used to set goals for myself, but that now seems like a waste of time;” and
“My daily activities often seem trivial and unimportant to me.”

Guess whether the correlation was positive or negative? Or read the study here, when it becomes published (it's not posted yet, but this at least rates a reminder in Outlook) .

TGIF and find purpose in your weekend. You'll live longer.

Chris Graham