The applicant brought an application under s. 684 of the Criminal Code for the appointment of counsel for his appeals against conviction and sentence for fraud over $5,000.
The court found insufficient merit in the conviction appeal to warrant the appointment of counsel, noting the applicant's admissions at trial and the discretionary nature of the trial judge's Rowbotham ruling.
However, the court found an arguable issue regarding the imposition of a fine in lieu of forfeiture on the sentence appeal.
The application was granted in part, with counsel appointed solely for the sentence appeal.
