The applicant, Anh Chiem, charged with first-degree murder, sought to quash a production order compelling the Law Society of Ontario (LSO) to disclose her complaints against the deceased lawyer.
The court dismissed the application, finding that the applicant lacked standing under s. 487.0193 of the Criminal Code, as only the party ordered to produce (the LSO) could initiate such a challenge.
The court also held that the Criminal Code provisions for production orders operate independently of the Law Society Act's disclosure criteria, and that issues of privilege or incrimination are addressed within the Code's framework or at the admissibility stage.
