Joshua Elcombe

The moving party, Glenn Bogue, brought three panel review motions before the Court of Appeal for Ontario, seeking review of single judge orders.

Two motions related to his appeal of a Law Society of Ontario license suspension, and the third concerned litigation over his mother's property.

The court dismissed all motions as frivolous, vexatious, and an abuse of process under Rule 2.1.02, finding that the moving party repeatedly failed to advance his appeals and misused the panel review procedure.

Additionally, the court revoked his existing fee waivers pursuant to section 4.10 of the Administration of Justice Act.

The self-represented litigant, Glenn Bogue, a suspended lawyer, filed multiple procedural panel review motions in the Court of Appeal concerning his appeal from a Law Society of Ontario suspension and a separate power of attorney litigation.

The court found these motions to be an improper use of the panel review procedure under s. 7(5) of the Courts of Justice Act, as they diverted judicial resources from the merits of the appeals and constituted an "endless cycle of appeals within an appeal" on procedural issues.

The judge issued directions to the Registrar to initiate a Rule 2.1.02 process to dismiss these unperfected procedural motions, review Mr. Bogue's existing fee waivers under s. 4.10 of the Administration of Justice Act, and temporarily restrict further filings from him until the panel review matters are resolved.

The Law Society of Ontario applied under s. 49.13 of the Law Society Act for an order to disclose confidential financial records of Rasik Behari Mehta to the Ontario Securities Commission's Joint Serious Offences Team (JSOT) for an investigation into alleged frauds by David Singh.

The court considered whether the s. 49.13(2) restrictions on disclosure applied, finding that the financial records were not "oral or written statements" and were not subject to solicitor-client privilege.

Applying a three-part test from Deloitte & Touche LLP, the court balanced the public interest in disclosure against confidentiality concerns, concluding that the public interest in investigating and prosecuting serious fraud outweighed any remaining confidentiality issues.

The application was granted.