Re: Formal Notice of Continuing Property Dispute and Court Proceedings – Court of King’s Bench File
WITHOUT PREJUDICE
Alberta Land Titles Office
710 4 Ave SW, Calgary, AB T2P 0K3
Re: Formal Notice of Continuing Property Dispute and Court Proceedings – Court of King’s Bench File No. 2501-19973
Dear Registrar / Alberta Land Titles:
I am writing to provide further formal notice regarding the continuing dispute concerning the titles to my properties formerly registered in my name and/or in the name of Sunny Investment Group Inc., which have subsequently been registered in the name of the Village of Standard.
Alberta Land Titles is already aware that litigation has been commenced concerning these matters, including Court of King’s Bench File No. 2501-19973.
I have previously provided Land Titles with documentation and evidence concerning the dispute. Notwithstanding the existence of these proceedings and my objections, I subsequently learned that title to the disputed properties was registered in the name of the Village of Standard.
I expressly dispute the validity and legal consequences of that transfer and reserve all rights to challenge the registration and seek appropriate relief through the Court.
There are also related ongoing proceedings and matters for which I am presently awaiting further written court documentation. On August 17, 2026, I attended the Calgary Court of King’s Bench Registry seeking the outstanding written court record, and I have made a further written request to the Court concerning that record.
Accordingly, this letter is intended to ensure that Alberta Land Titles has clear and continuing written notice that:
1. ownership of and entitlement to the properties remain actively disputed;
2. litigation concerning Land Titles and the properties remains unresolved;
3. I do not consent to or accept the transfer of the disputed properties to the Village of Standard;
4. I reserve the right to seek court orders affecting the registrations and titles;
5. I reserve the right to seek damages or other remedies arising from actions taken after notice of the dispute, subject to the evidence, applicable law and future court determinations; and
6. further dealings with the properties may become relevant to the continuing litigation.
I therefore respectfully request that this letter be retained as part of the relevant Land Titles correspondence and administrative record.
I further request that Land Titles preserve all records relating to these properties, including registration submissions, registration dates and times, pending-registration records, correspondence, internal notes, supporting documents, communications with the Village of Standard or its representatives, and records identifying the statutory or documentary basis upon which the transfers were accepted and registered.
I also respectfully request written confirmation of:
· receipt of this letter;
· the current registration status of the two disputed properties;
· the registration instrument or document numbers by which title was transferred to the Village of Standard; and
· whether any further instruments affecting these titles are presently pending registration, to the extent such information may lawfully be disclosed.
This letter is not intended to substitute for any application, caveat, Certificate of Lis Pendens, court order, appeal or other procedure that may be required under Alberta law. I expressly reserve the right to pursue any such procedure after obtaining legal advice and reviewing the outstanding court documentation.
Nothing contained in this letter constitutes a waiver, admission, abandonment, discontinuance or limitation of any existing or future claim or remedy.
Please place this correspondence on the appropriate administrative file and provide written confirmation of receipt.
Sincerely,
Peter Z. Pan
for himself and, where applicable,
Sunny Investment Group Inc.
All rights expressly reserved.
C: 587 437-1668
E: standardhotel1668@gmail.com
408-1826 16a St. SW Calgary, AB T2T 4J7
WITHOUT PREJUDICE
To: Village of Standard Office
120 Elsinore Avenue
PO Box 249
Standard, Alberta T0J 3G0
email: cao@villageofstandard.ca
Phone: 403-644-3968
Re: Properties formerly registered to Peter Z. Pan / Sunny Investment Group Inc. – Continuing Dispute, Pending Court Proceedings and Formal Notice to Preserve Rights
Dear Sir/Madam:
I am writing to the Village of Standard and its legal counsel to provide further formal notice concerning the continuing dispute involving my properties, municipal taxation, tax recovery proceedings, possession of the properties, and the subsequent transfer of title.
As you are already aware, these matters have been the subject of extensive correspondence and court proceedings. They remain disputed and unresolved.
I am presently awaiting the written court record arising from recent proceedings before the Court of King’s Bench. I attended the Calgary Court of King’s Bench Registry on August 17, 2026 to follow up regarding the outstanding written decision/order, and I have also written directly to the Judicial Assistant requesting confirmation and copies of the applicable written Reasons, Order, endorsement, or other court record.
Until that written record is received and its legal effect can be fully reviewed, I expressly reserve all of my rights and remedies.
For greater certainty, neither I nor Sunny Investment Group Inc. accept or acknowledge the lawfulness of the Village’s acquisition, possession, registration, transfer, disposition, encumbrance, sale, alteration, or other dealing with the disputed properties.
The Village has previously been provided with substantial documentation concerning, among other matters:
· my dispute respecting the alleged municipal tax arrears and associated penalties;
· monies held in trust toward municipal property taxes;
· my claims concerning the Village’s longstanding use of my property for snow dumping and the unpaid invoice arising from that use;
· disputes concerning assessments and taxation;
· disputes concerning the mobile home and related municipal charges;
· the continuing litigation and administrative proceedings concerning these matters; and
· my continuing objections to the Village taking or dealing with the properties while these disputes remain unresolved.
This letter constitutes formal written notice that the ownership, entitlement, financial accounting, municipal actions and transfer of the properties continue to be disputed.
Accordingly, I respectfully request that the Village and everyone acting on its behalf refrain from taking any further irreversible steps concerning the properties, including sale, transfer to third parties, demolition, substantial alteration, new encumbrances, or disposition of property or assets, until the outstanding court record has been received and the parties have had a reasonable opportunity to determine its effect and pursue any remedies available to them.
I further request that the Village preserve all documents, electronic records, correspondence, accounting records, tax records, assessment records, Land Titles communications, internal communications, photographs, inspection records, legal correspondence, and other evidence relating to these properties and the disputes between us.
Nothing in this letter constitutes a waiver, abandonment, admission or limitation of any claim, defence, appeal, application, action for damages, restitutionary claim, or other remedy that I or Sunny Investment Group Inc. may have.
Once the outstanding written court record is received, I will review it and determine what further legal steps may be necessary.
Please place this letter in the Village’s official records and provide a copy to all appropriate municipal officials and legal representatives involved in these matters.
I request written confirmation that this notice has been received.
Sincerely,
Peter Z. Pan
for himself and, where applicable,
Sunny Investment Group Inc.
All rights expressly reserved.
C: 587 437-1668
E: standardhotel1668@gmail.com
408-1826 16a St. SW Calgary, AB T2T 4J7