LAW SOCIETY TRIBUNAL
HEARING DIVISION
Date: April 20, 2026
Tribunal File No.: 25H-141
BETWEEN:
Law Society of Ontario Applicant
- and -
Patricia Marie Reilly Respondent
Before: Murray Walter Chitra
Heard: March 5, 2026, by videoconference
Appearances:
Ellisif Harris, for the applicant
Respondent, self-represented
Summary:
REILLY – Failure to co-operate – Books and records – The Law Society alleged that the Paralegal failed to co-operate with and respond to its investigation by not promptly and completely producing all information requested – The Paralegal acknowledged that she had not provided the requested materials and also stated that she had a disability which the Law Society failed in its duty to accommodate – The Paralegal did not provide any evidentiary support for her assertions - The panel found that the Paralegal had engaged in misconduct – The Paralegal was suspended indefinitely pending compliance and the completion of other suspensions – She was also ordered to pay costs of $1,000 to the Law Society.
REASONS FOR DECISION
1Murray Walter Chitra:– The Law Society filed a notice of application against Patricia Marie Reilly (the Paralegal) on October 6, 2025, alleging that she had failed to comply with Rule 9.01 of the Paralegal Rules of Conduct.
2Specifically, it asserted that since April 25, 2025, she had failed to co-operate in an investigation by not promptly and completely producing requested information, including books and records required to be maintained under s 18 of By-Law 9.
3This summary proceeding was scheduled to be heard by me on November 28, 2025. The parties appeared and the Paralegal requested an adjournment due for medical and family reasons. I adjourned the hearing to January 5, 2026.
4The rehearing reconvened that day. The Law Society requested an adjournment because of the illness of its only witness. With the consent of the Paralegal, the hearing was further adjourned to March 5, 2026. That hearing took place as scheduled.
5I found that misconduct had been established. I ordered the Paralegal’s licence be suspended indefinitely until she provided the outstanding requests and resolved other suspensions. This was to be followed by a two-month fixed suspension and the payment of costs in the amount of $1,000 within a year.
6These are my reasons.
BACKGROUND
7The Paralegal was licensed in 2012. She worked in Toronto as a sole practitioner.
8On July 11, 2025, her licence was indefinitely suspended for failure to co‑operate in a Law Society investigation until compliance, following which she was to serve a one-month fixed suspension. Cost of $1,500 were imposed.
9The Paralegal’s indefinite suspension remains in place. It was in effect during the course of this proceeding.
EVIDENCE
Law Society
10The Law Society’s evidence was provided by investigative counsel Quinn Read-Baxter. It was supported by affidavits with numerous appended documents.
11Her testimony and evidence disclosed that on November 3, 2024, the Law Society received a complaint from a former client of the Paralegal relating to a landlord and tenant application.
12The essence of the allegation was that the complainant had hired the Paralegal on a fixed fee basis. She had paid a retainer, but her application was never filed by the Paralegal. She stopped hearing from her. Communications, including requests for a refund, were not responded to.
13Starting November 21, 2024, the Paralegal was sent the first of three portal messages and a telephone voice message from Law Society Intake and Resolution staff. These informed her of the complaint and asking for certain information. The Paralegal did not respond to any of these communications.
14A formal investigation was authorized on April 14, 2025. In summary, the specific concerns identified were that the Paralegal may have:
misappropriated, mishandled or misapplied trust monies;
failed to provide legal services to the client in accordance with standards of competence and quality;
failed to communicate; and
failed to communicate or co-operate with the Law Society or the licensee’s insurer.
15Ms. Read-Baxter was assigned as investigator. Starting on April 28, 2025, she sent the Paralegal the first of a series of portal messages through LSO Connects. This is a secure platform to provide and receive documents from licensees. When a portal message is published it automatically generates a notification email to the recipient.
16Ms. Read-Baxter requested that the Paralegal provide the following information by May 19, 2025:
Written representations addressing all of the regulatory issues identified for investigation with each issue discussed under a separate heading.
A complete electronic copy of the original client file for the matters/transactions under investigation, including all solicitor’s notes, work produce and correspondence.
Client trust ledgers in accordance with By-Law 9, s 18(3), and the supporting documentation to support each transaction listed thereon. If you did not maintain a trust account during this period, please confirm this within your written representations.
A complete copy of all interim and/or final accounts for the matters/transactions under investigation, including documentation demonstrating delivery of those bills to the client.
17The Paralegal did not respond. She did not reply to follow-up messages on May 26 and June 11, 2025. She missed three deadlines.
18On June 24, 2025, two Law Society investigative counsel visited the Paralegal’s business address which was also her home residence. The Paralegal did not respond to her buzzer. A voice message was left.
19That same day, the Paralegal called the Law Society offices and spoke with Ms. Read-Baxer and another investigative counsel. The essence of this communication was that:
The Paralegal had talked to duty counsel and requested that communications be in written form.
She stated she was having trouble with the portal, including reading messages. Investigative counsel pointed out to her that she had been able to use the portal to report her annual continuing professional development hours.
There was a lot going on in her life. It was a struggle for her to read things online because she suffers from a traumatic brain injury. She was not trying to be disrespectful to her regulator.
20Later that day Ms. Read-Baxter telephoned the Paralegal. She acknowledged her request for paper copies. She explained the process to be followed to receive accommodation. The Paralegal said she would not participate in that accommodation process because it was “ridiculous”.
21On July 23, 2025, Ms. Read-Baxter called the Paralegal at her business number twice. She did not answer. On the second call, Ms. Read-Baxter left a voice message for the Paralegal a directing her to check her portal messages and extending her deadline to August 6, 2025.
22In her voice message Ms. Read-Baxer acknowledged that the Paralegal may require accommodation and again provided information about how to make such a request. She explained that medical information was required to properly assess what accommodation was necessary.
23That same day, Ms. Read-Baxter repeated this information in a written portal communication to the Paralegal. She offered to speak to her directly if she wished to discuss any challenges she might face in making an accommodation request.
24On September 23, 2025, Ms. Read-Baxter sent a final portal message stating that she had received no response or any requested information from the Paralegal, so the matter would be transferred to Litigation Services. That resulted in the notice of application before me.
25As of the date of this hearing, none of the requested information set out in para 16 has been provided. The investigation into the client complaint is stalled.
Paralegal
26The Paralegal acknowledged that she had not provided the requested material. However, she asserts that no one has suffered from the delay.
27She refunded the retainer to her former client. She testified that that even to this day that client still wants her to do work and calls her.
28She has good paper records. Apart from trust ledgers, she is able to provide most of the information required.
29She is a person with a long-standing disability that arose from a serious work-related accident in 1998. Her practice suffered because of COVID and she lost her office. She is living in poverty.
30The Law Society had failed in its duty to accommodate her. She received accommodation as a licensing candidate in 2011, so the Law Society was aware of her situation.
31The Paralegal did not file or provide any documents or material in support of her evidence. That includes medical, financial, or paper records relating to the complaint.
ANALYSIS
32Paralegal Rule 9.01(1) reads:
A paralegal shall reply promptly and completely to any communication from the Law Society and shall provide a complete response to any request from the Law Society.
33Meeting this requirement is a serious professional duty. It is an ethical obligation directed at ensuring that members of public can have confidence that when they raise concerns about the conduct of a legal professional that these will be promptly investigated and appropriate action taken, if required: Law Society of Upper Canada v Ghobrial, 2014 ONLSHP 5.
34It has been 17 months since the Paralegal received her first request for information into a public complaint about her. That includes requests for documents that she is required to maintain, secure and have readily available. To date, despite numerous requests and extensions, she has provided nothing.
35By any measure this is neither a prompt nor complete response as required. A complaint by a member of the public about her conduct is stalled.
36The Paralegal asserts disability. This may well be the case, but she has provided no evidence in support of this. She has received clear direction on multiple occasions on the process to follow to ensure that the necessary and appropriate accommodation is made available.
37The Paralegal has refused to engage in this process, deeming it to be “ridiculous”. This is unfortunate, but accommodation is a two-way street1.
38It is not enough to simply assert a disability. It must be grounded in medical evidence. Any required accommodation must be professionally assessed taking into account diagnosis, prognosis, and other relevant considerations. This is not a decision based on personal pronouncement.
39For the above reasons, I found the alleged professional misconduct has been established.
PENALTY
40The relevant factors governing the imposition of penalty are articulated in Law Society of Ontario v Aguirre, 2007 ONLSHP 46. The aspects that apply here include:
the Paralegal was the subject of a recent disciplinary sanction for similar misconduct;
the current misconduct has been ongoing for 17 months;
a complaint about her conduct remains outstanding, unresolved and investigation stalled; and
there may be extenuating factors, however no evidence has been provided to reliably establish any.
41This is a case that requires the application of progressive discipline. The normal penalty for a second failure to comply is a two-month fixed suspension. Examples include Law Society of Upper Canada v Shifman, 2010 ONLSHP 41, and Law Society of Ontario v Culliton, 2020 ONLSTH 103.
42Jurisprudence calls for this penalty to follow an indefinite suspension linked to the fulfillment of any outstanding requests: Law Society of Ontario v Owaisi, 2019 ONLSTH 92, Law Society of Ontario v Hans, 2021 ONLSTH 40, and Law Society of Ontario v Deliscar, 2021 ONLSTH 81.
43There is nothing before me that suggests that any variation from the above is warranted. The total absence of compliance in this and the failure to address the directions in the prior case compel indefinite suspension. It must be clear to the Paralegal that meeting her long-outstanding regulatory obligations must be her personal and professional priority.
COSTS
44That then leaves the matter of costs. The Law Society filed a bill of costs in the amount of $4,403. The Law Society is seeking payment of $2,000. The Paralegal stated that she had no ability to pay and that any such order would be punitive.
45The normal range of costs in simple summary hearing matters range from $2,000 to $5,000. That is reflected in the cases cited above.
46I do not doubt that the Paralegal’s financial situation may well be perilous. However, no specific details or evidence were offered. This must be balanced by the principle that a licensee should bear some portion of the expenses to the professions of the costs associated with their misconduct.
47Accordingly, I directed costs in the amount of $1,000 with a year to pay.
ORDER
48I ordered:
The respondent’s licence to provide legal services is suspended effective immediately and continuing indefinitely thereafter until, to the satisfaction of the Law Society’s Executive Director, Professional Regulation, or their designate, the respondent has provided a complete response to the requests made by the Law Society investigator in her portal messages dated April 28, 2025, and the corresponding case requirements published to LSO Connects.
The respondent’s licence to provide legal services is suspended for a period of two months, to start immediately upon the latter of:
a. the end of the suspension ordered at paragraph one, above; and
b. the end of all current or already pending suspensions of the respondent’s license under Part II of the Act.
The respondent shall comply fully with the terms of the Law Society’s Guidelines for Paralegals Who Are Suspended or Who Have Given an Undertaking Not to Provide Legal Services while suspended pursuant to this order.
The respondent shall pay costs to the Law Society in the amount of $1,000 on or before the deadline of March 4, 2027. This deadline may be extended by the Law Society in accordance with the By-Laws. Interest shall accrue on any overdue part of those costs at a rate of 4% per year.