LAW SOCIETY TRIBUNAL

HEARING DIVISION

Date: February 4, 2026

Tribunal File No.: 25H-168

BETWEEN:

Law Society of Ontario

Applicant

• and -

Michael Ezekiel Solomon

Respondent

Before: Margaret Leighton (chair), Gisele Chretien, Deborah Moriah

Heard: January 26, 2026, by videoconference

Appearances:

Kristina MacDonald, for the applicant

Jilian Siskind and Mohadeseh Bakhtiari, for the respondent

Summary:

SOLOMON – Adjournment – Interlocutory Suspension – The panel granted the Lawyer’s request for an adjournment of the motion hearing given the delivery of a complex, detailed, and lengthy affidavit shortly before the scheduled start of the hearing – The panel dismissed the Law Society’s request for an interim interlocutory suspension – The original hearing had been adjourned on consent after the Lawyer had undertaken not to provide legal services until a final order was made – While the allegations against the Lawyer are very serious, the existence of the undertaking and his undisputed compliance with it impacted the risk assessment.

REASONS FOR DECISION ON MOTIONS FOR ADJOURNMENT AND INTERIM INTERLOCUTORY SUSPENSION

1Margaret Leighton (for the panel):– The Law Society seeks an interlocutory suspension of the licence of Michael Ezekiel Solomon, the respondent paralegal, pursuant to s 49.27 of the Law Society Act, RSO 1990, c L.8, and Rules 5, 8, and 12 of the Tribunal’s Rules of Practice and Procedure.

2Mr. Solomon opposes the motion and seeks an adjournment of the hearing. His current LSO status is “Not Providing Legal Services” and he is also subject to an undertaking not to provide legal services.

3After hearing submissions from the parties, we adjourned the Law Society’s motion to February 27, 2026. We declined to exercise our discretion to order an interim interlocutory suspension. These are the reasons for our decisions.

THE ALLEGED MISCONDUCT

4In January 2025, the Law Society received a complaint from AA, whose company had retained Mr. Solomon in September 2021 to collect outstanding debts on its behalf. The complaint alleged that in some instances Mr. Solomon withheld a portion of funds collected and in others he failed to remit any of the funds collected. AA alleged that Mr. Solomon owed his company $784,447.86.

5In her affidavit affirmed November 21, 2025 (the first affidavit), the Law Society’s investigator states that her review of Mr. Solomon’s trust bank statements, general bank statement, and books and records led her to conclude that he held back $631,729.07 in trust funds from AA and his company.

6In September 2025, the Law Society received information about a civil proceeding commenced in May 2024 by a former client, ACRM, against both Mr. Solomon and his firm, Solomon Jones LLP, for the recovery of $600,000. The lawsuit alleges mishandling and/or misappropriation of trust funds. The Law Society notified Mr. Solomon that it was investigating these allegations on December 8, 2025.

7In her supplemental affidavit affirmed January 23, 2026 (the second affidavit), the Law Society’s investigator indicates that her review of the respondent’s handling of the AA and ACRM matters disclosed a pattern of concerning conduct. She characterised this as “skimming.”

8On October 28, 2025, the Law Society’s investigator advised Mr. Solomon that she would be reviewing his other accounts for a similar pattern. The second affidavit states that her review disclosed a similar pattern involving a third client between September 2022 and December 2023.

9Both affidavits describe the investigator’s ongoing requests for information and documents from Mr. Solomon. In the second affidavit she states that she has yet to be provided with the following:

• For the AA complaint:

Evidence the invoices in column “Funds Transferred to General Account from Column D” in Exhibit K to the first affidavit were sent to AA’s company.

• For the ACRM complaint:

Copies of the front and back of ALL cancelled cheques

Duplicate deposit book

Duplicate cash receipts book

Copies of incoming/outgoing wire transfers

ALL invoices/bills rendered to ACRM since July 1, 2021 to current, including:

Method by which each invoice/bill was sent to ACRM

Evidence showing each invoice/bill being sent to ACRM

10Mr. Solomon disputes all the Law Society’s allegations. Ms. MacDonald, on behalf of the Law Society, did not argue that he had failed to co-operate with the investigation.

PROCEDURAL HISTORY

11The Law Society’s notice of motion for an interlocutory suspension or restriction was filed November 20, 2025. The hearing was scheduled for December 1, 2025.

12At a proceeding management conference held November 28, Ms. Siskind asked to adjourn the December hearing. She argued that the Law Society’s motion materials had been served four days before and she was not available on the scheduled motion date.

13The Law Society consented to the adjournment on the condition that Mr. Solomon deliver an undertaking not to provide legal services in a form acceptable to the Law Society. He did so that day. In accordance with the undertaking, Mr. Solomon’s licence is in non-practising status until a final order is made in this file. As a result, the December motion date was vacated and re-scheduled for January 26, 2026.

14On January 22, 2026, Mr. Solomon’s counsel requested an adjournment of the January 26 date on the basis that the Law Society had not served its factum as required by the Rules and that she had been advised the Law Society intended to deliver a supplemental affidavit.

15The Law Society’s representative responded the next day to advise that its factum was served and filed on November 21, 2025, as set out in the Law Society’s affidavit of service. She also indicated that the supplemental affidavit had now been served. It was her position that an adjournment was unnecessary.

SUBMISSIONS

16Before us, the respondent maintained that his counsel had not been served with the Law Society’s factum in advance of the December motion in contravention of the Tribunal’s Rules. Although this was brought to the Law Society’s attention in December it was not rectified until January 23.

17More concerning was the delivery of the second affidavit at noon on the Friday before the hearing. The second affidavit is 4,508 pages long and contains additional serious allegations. It includes very detailed accounting information which necessitated the retention of an accountant to assist in analysing its contents. Its length and its complexity made it impossible to respond at the hearing on Monday.

18Ms. Siskind asked that the motion be adjourned until at least the week of February 23. She argued this was fair and reasonable given the Law Society’s acknowledgment that Mr. Solomon has co-operated with the Law Society, is not practising, and is subject to the undertaking not to provide legal services.

19On behalf of the Law Society, Ms. MacDonald noted that this was the second request for an adjournment and that Mr. Solomon had been late providing his required disclosure. While agreeing that the second affidavit contains new allegations and is voluminous, she argued that it is primarily based on communications between the investigator and Mr. Solomon.

20That said, Ms. MacDonald acknowledged very fairly that more time would be needed to respond and did not oppose an adjournment to the first week of February. In making this concession she also advised that the Law Society has no concerns with Mr. Solomon’s compliance with his undertaking and that the alleged misconduct is with respect to historic transactions. It was unclear to her how an accountant could provide advice with respect to the issue of risk which is the issue on this motion.

21However, if we were considering adjourning to the end of February, Ms. MacDonald urged us to order an interim interlocutory suspension as added insurance against risk. She argued that, while the general public might not see an additional two-week delay as a cause for concern, given Mr. Solomon has been abiding by his undertaking since November, a longer delay might risk loss of public confidence in the administration of justice.

ADJOURNMENT GRANTED

22Where an adjournment of an interlocutory suspension motion is requested, both fairness to the licensee and risk of harm to the public and the public interest in the administration of justice must be considered: Law Society of Ontario v Bogue, 2017 ONLSTH 119 at paras 12-13.

23While we are troubled by the fact that this is the second request to adjourn the motion, we readily accept that the delivery of a complex, detailed, and extremely lengthy affidavit containing new allegations the Friday before this hearing was to proceed on the Monday would make mounting an effective defense extremely difficult. We agreed that requiring Mr. Solomon and his counsel to proceed with the hearing on the Monday would be unfair. Given the additional allegations and complexity, we were satisfied that it was fair and reasonable to permit a longer adjournment to February 27, 2026.

INTERIM INTERLOCUTORY ORDER UNNECESSARY

24We then considered whether an interim interlocutory suspension was necessary. This analysis requires an assessment of urgency, in the sense of likelihood and severity of risk prior to the motion hearing on one hand, and of the adverse impact of an interim order on the licensee on the other. Law Society of Ontario v Denchik, 2025 ONLSTH 166, outlines the analysis at paras 4-8:

4Requests for interlocutory suspensions/restrictions (interlocutory orders) are governed by s 49.27(2) of the Law Society Act, RSO 1990, c L.8 (the Act), which provides that:

The Hearing Division may only make an interlocutory order suspending a licensee’s licence or restricting the manner in which a licensee may practise law or provide legal services if there are reasonable grounds for believing that there is a significant risk of harm to members of the public, or to the public interest in the administration of justice, if the order is not made.

5An interlocutory order may not be made unless there are reasonable grounds for believing that there is a significant risk of harm as specified in s 49.27(2) of the Act. …

6Because interim orders are a type of interlocutory order, it follows that interim orders may not be made unless the threshold established by s 49.27(2) of the Act is met. …

7In assessing whether the s 49.27(2) threshold has been met for the purpose of an interim order, a panel must consider the evidence that is before it. Of course, the evidence before the panel ultimately hearing the motion may well be different, but that does not change the need to act on the current evidence.

8But meeting the s 49.27(2) threshold does not mean that an interim order must be made, only that it can be. There is still a discretionary decision that must be made. In exercising that discretion, it is important to recognize that interim orders address risk of harm and that it is the risk of harm prior to the hearing of the motion that must be considered. This is a much shorter period of risk than must be considered for an interlocutory order at the motion hearing.

25The allegations against Mr. Solomon are very serious and involve significant amounts of funds held in trust for clients. If proven, they fall within the category of misconduct to which presumptive revocation applies. But for the existence of the undertaking, we would have had no hesitation in concluding that an interim interlocutory order was appropriate based on the evidence before us, notwithstanding Mr. Solomon vigorously contests the allegations. Such an order would address both any ongoing risk to the public and the risk that failure to order a suspension would undermine public confidence in the administration of justice, and the Law Society’s ability to self-regulate.

26The undertaking, and Mr. Solomon’s undisputed compliance with it, changes that risk assessment. First, there is no evidence of an ongoing risk to clients or other members of the public. Mr. Solomon is not providing legal services. He does not operate any trust accounts. He is not practising as a paralegal. He is complying with his undertaking.

27Second, both this hearing and our reasons are public. Members of the public attended the hearing. Members of the public may read these reasons. Although the undertaking is a private agreement between Mr. Solomon and his regulator, through this hearing and our reasons the constraints it imposes on him have become public. This addresses the second branch of the test for making an interlocutory order – the need to maintain the public’s confidence in the administration of justice. It will be evident to members of the public that the Law Society is engaging in a rigorous investigation of alleged misconduct and carrying out its obligations as regulator of the professions to protect the public interest in the administration of justice.

28In these very particular circumstances, we declined to exercise our discretion to make an interim interlocutory order.

ORDER

29The motion is adjourned until February 27, 2026.