Law Society of Ontario v. Bush, 2026 ONLSTH 64

LAW SOCIETY TRIBUNAL

HEARING DIVISION

Date: March 31, 2026

Tribunal File No.: 24H-088

BETWEEN:

Law Society of Ontario

Applicant

• and -

James Jeffrey Bush

Respondent

Before: Margaret Leighton (chair), Paula Callaghan, John F. Spekkens

Heard: January 8, 2026, by videoconference, and by written submissions

Appearances:

Amanda Worley, for the applicant

Respondent, self-represented

Summary:

BUSH – Capacity – Having earlier found that the Paralegal was and continues to be incapacitated within the meaning of the Act, the panel considered the issue of the appropriate order – The panel concluded that, given the Paralegal’s prognosis, lack of insight into his condition, and unwillingness to engage in therapy or treatment, the only appropriate disposition which protects the public was the revocation of his licence – The Paralegal’s licence was revoked – The panel ordered that he pay $15,000 in costs to the Law Society only once he reapplies for a licence.

REASONS FOR DECISION ON DISPOSITION AND COSTS

1Margaret Leighton (for the panel):– In Law Society of Ontario v Bush, 2025 ONLSTH 119 (the capacity decision), we found the respondent, James Jeffrey Bush, was and continues to be to be incapacitated within the meaning of s 37 of the Law Society Act, RSO 1990, c. L.8 (the Act). We must now decide what capacity order should follow that finding. We must also consider whether Mr. Bush should pay some portion of the over $100,000 in legal costs incurred by the Law Society for the investigation and prosecution of this matter.

2In the capacity decision, we found:

[175] The Licensee has a disability related to neurodevelopmental disorder and/or personality features interacting with and/or exacerbated by a vascular neurocognitive disorder caused by the 2007 basal ganglia bleed/stroke. These conditions have resulted in significant executive dysfunction since at least 2016, but likely prior to that date.

[176] Mr. Bush’s inability to recognise his deficits and their effect on his conduct is the consequence of his anosognosia rather than obliviousness or contrariness. This is genuinely a case of incapacity rather than misconduct.

[177] Even if we accept the possibility that Mr. Bush may be able to meet some of his obligations some of the time, this is not sufficient reason for us to conclude that the public interest would be protected by determining that he has the capacity to continue to provide legal services: Law Society of Ontario v Bogue, 2019 ONLSTH 107 at para 27.

[178] Mr. Bush’s disability renders him incapable of providing legal services to the standard of a competent paralegal. It prevents or severely limits his ability to serve clients, interact with opposing parties and counsel, and participate in adjudicative processes to the standard of a competent paralegal.

3Section 40 of the Act provides:

40 (1) Subject to the rules of practice and procedure, if an application is made under section 38 and the Hearing Division determines that the licensee is or has been incapacitated, the Division may make one or more of the following orders:

1. An order suspending the licensee’s licence,

i. for a definite period,

ii. until terms and conditions specified by the Hearing Division are met to the satisfaction of the Society, or

iii. for a definite period and, after that, until terms and conditions specified by the Hearing Division are met to the satisfaction of the Society.

2. An order that the licensee obtain or continue treatment or counselling, including testing and treatment for addiction to or excessive use of alcohol or drugs, or participate in other programs to improve his or her health.

3. An order restricting the areas of law that the licensee may practise or in which the licensee may provide legal services.

3.1 An order restricting the legal services that the licensee may provide.

4. An order that the licensee practise law or provide legal services only, i. as an employee of a person approved by the Society, ii. as an employee or partner, and under the supervision, of a licensee approved by the Society, or iii. under the supervision of a licensee approved by the Society.

5. An order that the licensee report on his or her compliance with any order made under this section and authorize others involved with his or her treatment or supervision to report thereon.

6. Any other order that the Hearing Division considers appropriate.

(2) The failure of subsection (1) to specifically mention an order that is provided for elsewhere in this Act does not prevent an order of that kind from being made under paragraph 6 of subsection (1).

4To reach an appropriate and fair disposition of this application we must consider and balance Mr. Bush’s individual rights and circumstances as a person with a disability, in this case a brain injury and a personality disorder, with the protection of the public: Law Society of Ontario v Stewart, 2019 ONLSTH 118 at para 13. For the reasons which follow we have concluded, reluctantly and with considerable empathy for Mr. Bush, that we must revoke his paralegal licence.

PRELIMINARY MATTERS

5At the outset of the disposition hearing and without notice to the Tribunal, Mr. Bush raised several preliminary matters. He asked that the hearing be adjourned for approximately one month. He asked that that I recuse myself as chair. Finally, he asked to be permitted to make his submissions in writing.

Adjournment refused

6This was Mr. Bush’s third request to adjourn the disposition hearing. Mr. Bush provided four reasons to support his renewed request to adjourn:

1. He expected a decision on his complaint about Dr. Domitrovic from her regulator within days. If his complaint is upheld, he submitted that this would impact our conclusions concerning her report.

2. He was awaiting results of blood tests and had an MRI exam scheduled for January 12. He argued this information would assist us in considering whether he could continue to practise, perhaps with restrictions.

3. He had commenced a judicial review to the Divisional Court of our decision. His application was issued in October but had not been served on the Law Society because he was not required to do so for six months. In addition, he had commenced two applications in Superior Court on January 6, 2026. The first sought an injunction, stay, mandamus and declaratory relief against LSO and his E&O providers. The second challenged the jurisdiction of the deputy judge to make the 2017 contempt order. It also names the LSO. Neither had been served on the Law Society. Mr. Bush argued that if the judicial review was allowed or the Superior Court agreed there was no jurisdiction to have made the contempt order then “everything else should go away.”

4. His application for benefits from the Ontario Disability Support Program was refused on December 19. He had until January 19 to request a review of the refusal. He submitted that we should await the outcome of this review.

7The Law Society opposed any adjournment. Ms. Worley argued that Mr. Bush presented no evidence of exceptional circumstances to support his request or meet the test for adjournment as set out in the Tribunal’s Practice Direction on Adjournments. In her submission, it is not in the public interest to delay this hearing.

8The Tribunal began canvassing for a continuation date in early October. This hearing date was set on October 20 after consulting with the parties. Mr. Bush had asked that the hearing be scheduled in the new year rather than December because that was a busy time for his banquet hall job. His request was accommodated.

9In December we refused an earlier request to adjourn until the decision on his complaint to Dr. Domitrovic’s regulator was issued. That he now knew a decision was pending does not support an inference that the decision would have any effect on our findings of incapacity.

10Updated blood work results or the results of an MRI would not change Dr. Domitrovic’s conclusion, based on her comparison of the 2012 and 2020 CT scans, that there is evidence of increased brain atrophy and encephalomalacia at the site of Mr. Bush’s basal ganglia hemorrhage.

11Mr. Bush acknowledges that his judicial review application is vulnerable to dismissal as premature. In any event, Mr. Bush chose not to pursue this remedy in a timely manner.

12The application attacking the contempt order is also vulnerable to dismissal on the basis of delay. Moreover, if Mr. Bush had read the capacity decision, which he repeatedly stated he had not and would not read, he would understand that the findings of fact concerning his behaviour in the garnishment proceeding are what is relevant to our assessment of incapacity, not whether the deputy judge had jurisdiction to hold him in contempt.

13How an as yet to be commenced review of the ODSP denial would affect the disposition of this application is entirely speculative. While we found Mr. Bush to be incapacitated within the meaning of the Act and therefore unable to carry out the functions of a competent paralegal, what constitutes “a substantial physical or mental impairment that is continuous or recurrent” for the purposes of obtaining ODSP benefits is an entirely different test. It also does not take into consideration protection of the public or the public interest in the administration of justice.

14We refused the adjournment. We were satisfied it was yet another unmeritorious attempt to delay the conclusion of this proceeding.

Recusal

15Mr. Bush argued that my tone and language was evidence of bias towards him. In particular he noted my expression of dismay when I learned at the December case conference that he had still not read the capacity decision. In addition, I had refused his requests to adjourn and/or to extend time without citing case law, and I did not ask for his submissions before making a hearing date peremptory on him. He also disagreed with my ruling concerning Dr. Domitrovic’s use of his medical records. Finally, I had not offered him further time to prepare for the voir dire after clarifying the information in my March 2025 endorsement.

16Mr. Bush bears the onus of demonstrating real or perceived bias. This is a high burden requiring cogent evidence informed by the underlying presumption of the impartiality of adjudicators: Cojocaru v BCWH, 2013 SCC 30 at para 22. Further, as Justice Doherty commented in Kelly v Palazzo, 2008 ONCA 82 at para 21, “(I)t takes much more than a demonstration of judicial impatience with counsel or even downright rudeness to dispel the strong presumption of impartiality.”

17Bias or a reasonable apprehension of bias is assessed from the perspective of the objective observer who must consider the context in which the allegations arise and ask:

… what would an informed person, viewing the matter realistically and practically — and having thought the matter through — conclude. Would he think that it is more likely than not that [the decision-maker], whether consciously or unconsciously, would not decide fairly: Yukon Francophone School Board, Education Area #23 v Yukon (Attorney General), 2015 SCC 25 at para 20.

18In this case that context includes the past 10 days of hearing as well as numerous case conferences. The capacity decision describes multiple instances where Mr. Bush failed to follow our directions, resisted our attempts to focus his evidence or submissions, and failed to use hearing time effectively. This delayed and complicated the hearing process. At the same time, it frustrated our attempts to assist Mr. Bush to understand the case he needed to meet and to provide us with relevant evidence and coherent argument. My genuine distress at Mr. Bush’s refusal to read the capacity decision was triggered by a concern that he would be unprepared to meet the Law Society’s arguments asking for revocation of his licence.

19His complaint about the voir dire relates to my March 27, 2025 endorsement. Mr. Bush did not raise any concerns at the time the endorsement was issued or on the resumption of the hearing in May 2025. I corrected myself on the record with an apology at the outset of the May 12 hearing. Mr. Bush accepted my apology and confirmed that my correction was in fact consistent with his own understanding. He did not ask to adjourn the hearing for that reason.

20The March endorsement was issued almost one year ago. If Mr. Bush genuinely was concerned about its contents, he ought to have raised those concerns before January 2026. Having failed to do so in a timely manner, he has waived his right to pursue this issue.

21Mr. Bush failed to provide any cogent or compelling evidence to support recusal. His request that I recuse myself was dismissed.

Written submissions

22We allowed Mr. Bush until February 6 to provide his submissions in writing. Ms. Worley was permitted to provide reply submissions in writing.

23On January 24, Mr. Bush asked for an additional 7-10 days to deliver his submissions. He explained that he needed additional time because he had not yet picked up a USB stick containing documents he requested from the Law Society the week before. We note these documents were already provided to him last year as part of the Law Society’s disclosure. However, because the recent blizzard would make picking up the USB stick from the Law Society’s offices difficult, we extended the deadline for submissions to February 9, 2026.

24On February 8, Mr. Bush sent an “urgent” request to extend the deadline until February 13. In support he advised that he prefers not to have matters due on a Monday, particularly Mondays during the coldest or hottest months of the year, his office is very cold, he is out of his medications, he continues to have ongoing problems with his landlord, his application for judicial review related to the finding of contempt has finally been issued by the Divisional Court, and he has been in recent contact with the College of Psychologists concerning his complaint about Dr. Domitrovic. In another letter Mr. Bush advised that he hoped to obtain and submit character letters and references.

25This request was refused. We were satisfied it was yet another attempt to delay the proceeding. Mr. Bush was directed to file his submissions or risk our declining to accept and consider them. Despite this warning he did not file his submissions until late on February 16. The submissions did not reference any of the documents he had requested from the Law Society or attach character letters. They exceeded the set page limit we had set but, at the same time, contained several paragraphs detailing what he would not address because of page limitations. They were not formatted correctly; several pages were in all caps and contained multiple typos. They included a garbled list of case references without coherent submissions to support them.

26The written submissions make evident Mr. Bush’s inability to understand and respond to the issues he was expected to address at the disposition hearing. He only vaguely refers to possible order terms or provides arguments to rebut the Law Society’s request for revocation. Instead, he repeats many of the arguments made during the capacity hearing. The written submissions are yet further proof of Mr. Bush’s executive dysfunction. They document his inability to fully understand legal issues and to organise and deliver written advocacy in a timely and coherent manner.

Preparation for the disposition hearing

27At the November case conference, I encouraged Mr. Bush to speak to duty counsel who might assist him to prepare for the disposition hearing. Mr. Bush said that duty counsel had not assisted him in the past and he was skeptical they would provide any meaningful assistance.

28Mr. Bush confirmed that he would lead evidence to support a lesser penalty and provide letters to support his position that the Law Society is “out of bounds”. He was directed to disclose and produce any evidence on which he intended to rely as well as witness statements in accordance with Rule 10.5(1) no later than 10 days before January 8, 2026.

MR. BUSH’S EVIDENCE AND SUBMISSIONS

29Mr. Bush failed to comply with our direction. Instead, on January 5, he delivered almost 500 pages of unindexed and disorganised materials. The majority addressed misuse of alcohol, use of opiates, and chronic pain. As we explained in the capacity decision, we accept Mr. Bush has struggled with these conditions. However, as Dr. Domitrovic did not find them to be significant contributing factors to the executive dysfunction affecting judgement, organisational, and intellectual capacity caused by his neurodevelopmental disorder and personality disorder interacting with the brain injury he suffered in 2007, this information was largely irrelevant to the issue now before us.

30Of the materials produced, three were relevant and marked as exhibits. The first was an updated medical note from his family physician advising that Mr. Bush continues to reduce his pain medication use and has limited his alcohol intake as well as his soft drink consumption. The letter goes on to advise that Mr. Bush reports he will experience “negative physical and mental health consequences” if unable to work as a paralegal. It is silent concerning any proposed treatment or therapy which might address Dr. Domitrovic’s diagnoses.

31The second was a letter dated December 16, 2025 from the Ontario Disability Support Program denying Mr. Bush’s application for disability benefits. The third was a reference letter from Mr. Bush’s employer at the banquet hall where he has worked for several years and to whom he had provided legal services in the past.

32Mr. Bush began his “evidence” by referring to a list of 41 points which he argued we should consider in deciding disposition. While we allowed him to take us through the entire list, we concluded that only the three exhibits discussed above, and his testimony concerning the May 16, 2024 addendum to Dr. Domitrovic’s report and possible employment opportunities were relevant to our determination.

Dr. Domitrovic’s addendum

33In her addendum Dr. Domitrovic addressed Mr. Bush’s ability to return to work as a paralegal in a supervised position or as an employee. He is correct that, on cross-examination, Dr. Domitrovic agreed this was a possibility.

34Mr. Bush continues to argue that because the Law Society did not challenge the testimony, it therefore should be accepted. However, we addressed this argument and provided reasons why we did not accept it in the capacity decision: see paras 118-119.

35In his written submissions Mr. Bush continues to argue that:

I am capable to fulfill all of my Law Society obligations, the panel has summary suspensions that were almost immediately rectified to the satisfaction of the Law Society.

The panel has NO specific evidence before it that says I cannot, the Law Society totally relies on an “expert” report which basis is medical reports from 2007- 2014 to which the Law Society already had. (sic, bold in original)

36This submission simply ignores Dr. Domitrovic’s report and her very comprehensive findings.

37Mr. Bush argues that his case may be distinguished from Law Society of Ontario v Hutton, 2023 ONLSTH 161, because we had no medical evidence on which to base our findings or to conclude that his conduct had brought the system of justice into disrepute.

The panel having medical evidence before it, and this was what I take to be the key to what they had to say, and this panel does not have that, in fact it was part of my “defence” that none of the capacity cases really are applicable based on facts ect(sic) to me.

38In the capacity decision we explained why the evidence led us to conclude he was unable to provide legal services to the standard of a competent paralegal. We appreciate he does not accept our conclusions, but this hearing was his opportunity to argue for a disposition short of revocation that would permit him to continue to practise while protecting the public and public confidence in the legal professions. He failed to take up that opportunity.

Supervised employment

39Mr. Bush testified that he believed he could come up with a proposal to satisfy the Law Society but did not intend to seek any job offers until after the hearing. At that point he would provide Ms. Worley with written proposals in hopes of reaching a joint resolution. He took this position despite having been told the purpose of this hearing and the need to present his proposals for consideration by the Law Society and our panel.

40Mr. Bush testified about his informal conversations with staff in the small claims courts as well as discussions with an individual who works with a payday loan company. He suggested there were a number of possible options short of revocation available to us. We could:

• Permit him to work as an employee or contractor under either a lawyer or paralegal.
• Permit him to work in house or as a contract employee for any company as a paralegal.
• Permit him to work as an instructor in a paralegal program offered by a private or public college.
• Permit him to do agent work as a paralegal under supervision of a lawyer or a paralegal. He stated he would not accept payments from clients in this position.
• Permit him to practice with restrictions for six months during which he would work collaboratively with LSO to “move forward.”
• Permit him to have a lawyer or paralegal as a supervisor.
• Permit him to work as an employee of the Ministry of Attorney General in the small claims court.
• Permit him to work for a collections agency as a paralegal or work with a lawyer who has a collection agency but not as a paralegal.

41We have no evidence that a prospective supervisor or employer is or would be prepared or willing to employ Mr. Bush as a paralegal. Mr. Bush expressed hopes but no meaningful plan for such a position. More troubling, it is obvious Mr. Bush remains unable to appreciate the consequences of his brain injury and diagnosed disorders on his capacity to function as a paralegal. He offered no evidence as to how his executive dysfunction and cognitive deficits could be effectively managed even in a highly supervised work environment.

42Finally, Mr. Bush declined to propose any draft orders. In his written submissions, he explained “I view it by doing so would or at the very least might defeat my overall position(s) which I will articulate to some degree in these materials.”

Recent medical note

43We agree that the updated medical note suggests Mr. Bush’s general health is better. However it does not offer any plans or treatment proposals to address or assist Mr. Bush with managing the personality and behavioural issues (for example procrastination, document management and comprehension, organisation, communication) that so obviously and so detrimentally affect his ability to work as a paralegal.

Refusal of ODSP

44Mr. Bush reasons that he is not incapacitated because his application for disability benefits was refused when that application relied on Dr. Domitrovic’s reports. He did not address the fact that the Ontario Disability Support Program applies an entirely different statutory purpose and test for applications for benefits.

Ungovernability

45In his written submissions Mr. Bush states, “I will not have it said that I am ungovernable.”

46This was never the Law Society’s position. In making this submission Mr. Bush circles back to his earlier, irrelevant arguments that it was unfair to proceed with the capacity application before concluding his outstanding conduct proceedings. Mr. Bush appears to continue to misunderstand the nature of this application and/or refuses to accept his role in agreeing to undergo an assessment rather than proceed directly to a penalty hearing.

LAW SOCIETY’S POSITION

47Ms. Worley acknowledged that, where there is a finding of present incapacity, the LSO usually asks for indefinite suspension until the licensee has received treatment and is fit to return to practice with monitoring and reporting requirements: for example, Hutton, above.

48In this case, she argued such an order is not in the public interest given the complex nature of Mr. Bush’s neurological and behavioural deficits. Moreover, Dr. Domitrovic’s opinion was that these conditions would not improve over time and, with respect to the mild vascular neurocognitive disorder, might become more disabling: capacity decision at paras 102-111.

49While agreeing that Dr. Domitrovic’s May addendum does not suggest Mr. Bush will never be able to engage in competitive employment, it also does not suggest when or exactly how he might do so. This is because she found the executive dysfunction associated with his personality disorder and his mild vascular neurocognitive disorder with behavioural disturbance

… are permanent (conditions) and have no specific medication or assistive device indications; they are also generally unresponsive to other types of intervention, including psychotherapy or cognitive rehabilitation, in all but the most motivated and insightful of patients. Furthermore, the mild vascular neurocognitive disorder appears to have worsened since 2008 and could progress to a major neurocognitive disorder or dementia. Minimizing vascular risk factors (e.g., hypertension; type 2 diabetes) through appropriate medication, diet and exercise is important in all stroke survivors to prevent further strokes or additional sequelae and should be adopted by Mr. Bush; this cannot undo any permanent brain changes he has sustained, however.

50Given this finding, Ms. Worley argued there is no reasonable prospect Mr. Bush will ever be well enough to return to practice as a paralegal. Thus, the only appropriate and reasonable outcome which can protect the public interest is revocation.

51In her view an indefinite suspension would be unfair to both the Law Society and to Mr. Bush as it would require ongoing monitoring of his medical condition where there is no realistic hope of improvement given the limited therapeutic options available and Mr. Bush’s poor prognosis.

52In addition, unlike in Hutton, there is no expert evidence to assist the parties and us in crafting the terms of such an order, which would require:

• a term suspending the licensee until he receives recommended treatment and obtains a fresh medical opinion confirming he is no longer incapacitated;
• a term imposing appropriate medical monitoring for a period after his return to practice; and
• a term imposing appropriate practice restrictions for a period after return to practice.

53In the absence of expert evidence, she argued it would be exceedingly difficult to assess what would be appropriate for Mr. Bush, given that his conditions include permanent brain damage.

ANALYSIS

54We accept that Mr. Bush’s general health may continue to improve as a result of his recent and commendable efforts to address diet, alcohol and opiate use. However, there is no evidence these important lifestyle changes can reverse the ongoing consequences of the brain injury caused by his 2007 stroke and its impact on his pre-existing neuropsychological disorders. Based on the expert evidence before us, we find that Mr. Bush’s disability is one which offers little prospect for recovery or improvement.

55In Hutton, Law Society of Ontario v Bogue, 2020 ONLSTH 21, and Law Society of Ontario v Burgess, 2021 ONLSTH 25, there was evidence before the panels that treatment was available for the licensees’ disabling condition and, if treatment was successful, the licensees could return to practice subject to a lengthy period of supervision. That is not the evidence before us. Mr. Bush’s condition is much closer to the circumstances in Law Society of Upper Canada v Argiris, 2013 ONLSHP 17, Law Society of Upper Canada v McCusker, 2013 ONLSHP 53, and Law Society of Upper Canada v Borden, 2014 ONLSHP 2. The licensees in those matters were diagnosed with permanent brain injuries or disease (diffuse small vessel cerebrovascular disease, alcohol induced persistent amnesic disorder, and Alzheimer’s disease). Their conditions, like Mr. Bush’s, were both permanent and likely degenerative.

56We have no doubt that Mr. Bush genuinely believes that the allegations of misconduct which, in part, led to the capacity investigation are unfounded. He either refuses to accept or is unable to appreciate that, while the misconduct allegations initially triggered questions about his capacity, Dr. Domitrovic’s findings following her extensive neuropsychological assessment were the reason the Law Society revived the capacity investigation and commenced this application.

57Similarly, Mr. Bush refuses, or is unable, due to his anosognosia, to understand the nature of his disability. Throughout this proceeding he has displayed a lack of insight into his behaviour and how it affects his intellectual abilities and capacity to make reasonable decisions and respond appropriately. He does not appreciate that his inability to follow directions, comply with rules and deadlines, or follow instructions is linked to his executive dysfunction and disability. His evidence and submissions provide no realistic path to a return to practice.

58Despite this, we wrestled with whether we could devise a Hutton type order to support an indefinite suspension. We have reluctantly concluded that, given Mr. Bush’s prognosis, lack of insight into his condition, and unwillingness to engage in therapy or treatment, it would be doomed to fail. There is simply no evidence on which we could create an order to replicate Hutton and its protections. Thus, the only appropriate disposition which protects the public is revocation of Mr. Bush’s licence.

COSTS

59The Law Society’s bill of costs totalled more $100,000. Ms. Worley explained that the Law Society had incurred almost $60,000 in counsel time. The remainder is attributable to Dr. Domitrovic’s assessment and testimony, and transcripts.

60Ms. Worley agreed that it was unusual to seek costs in capacity matters. Hutton and Bogue are examples of exceptions to that practice. She argued that Mr. Bush’s conduct – his failure to follow directions, the need to vacate a hearing day because he had not arranged for his witness to attend, and his inability to organise and prepare his documents – resulted in increased costs. She noted that substantial hearing time was spent trying to assist Mr. Bush to refocus his evidence and submissions and understand the case he was expected to address. This caused delay and wasted adjudicative resources.

61Ms. Worley argued that, at a minimum, he should be required to pay something, perhaps $15,000, toward the Law Society’s costs. She was open to payments over time.

62In his written submissions Mr. Bush argued that any submissions on costs would be premature and would “work against my interests and perhaps be detrimental and prejudicial. Further by doing so would take up space that might best be utilized for a direct reply to the Law Society.”

Analysis

63We agree that Mr. Bush should pay something toward the cost of this proceeding. His conduct throughout this hearing caused delay and wasted adjudicative resources. In our view this delay was frequently intentional.

64We do not agree that assessing costs is premature. Mr. Bush has known since the beginning of January that the Law Society intended to seek costs from him and why.

65Mr. Bush provided no evidence of impecuniosity. We know he has a part-time job and derives income from his debt purchasing endeavours. That said, we understand that he continues to have issues with his landlords and considers his housing to be precarious.

66We consider a contribution of $15,000 toward costs exceeding $100,000 to be exceptionally fair and reasonable. However, because this is a capacity proceeding where costs are not ordinarily awarded and we have declined to order an indefinite suspension as in Hutton and Brogue, our costs order will not take effect unless and until Mr. Bush applies for re-admission to the Law Society.

ORDER

67For these reasons we make the following order:

1. The respondent’s licence is revoked effective immediately.

2. The respondent shall comply fully with the terms of the Law Society’s Guidelines for Former Paralegals Whose Licences Have Been Revoked or Who Have Been Permitted to Surrender Their Licences.

3. The respondent shall pay costs to the Law Society in the amount of $15,000. The costs deadline is 12 months after the date of any application by the respondent to the Law Society of Ontario for licensing.