Executive Summary: Key Legal and Evidentiary Issues

• The court considered whether a non-lawyer could represent a corporation in appellate proceedings under Rule 15.01(2).

• The integrity of the justice system and the professional standards expected of legal advocates were central to the court’s analysis.

• The applicant’s representative’s history of submitting fabricated legal citations and authorities was a significant evidentiary concern.

• The court weighed access to justice against the risks and burdens posed by non-lawyer representation.

• The decision highlighted the lack of regulatory oversight and accountability for non-lawyer representatives.

• Costs were awarded to the responding party due to the conduct of the applicant’s representative.

Facts of the case

Stile Carpentry Ltd., through its representative Peter Paraskevopoulos, sought an extension of time to perfect an appeal from a judgment issued by Justice Ohler on June 27, 2025. Mr. Paraskevopoulos, who is not a lawyer but is the father of the corporation’s sole director, applied for leave to represent the corporation in the Court of Appeal under Rule 15.01(2) of the Rules of Civil Procedure. He had previously represented Stile Carpentry Ltd. in other legal proceedings and provided a shareholders’ resolution authorizing him to act on behalf of the corporation.

Legal framework and policy terms

The main legal issue revolved around Rule 15.01(2), which generally requires corporate parties to be represented by a lawyer in court proceedings, except with leave of the court. The court emphasized that granting such leave is exceptional and should not become routine, as it could undermine the purpose of the rule. The analysis referenced previous appellate decisions, including GlycoBioSciences Inc. v. Industria Farmaceutica Andromaco, S.A., de C.V., which clarified that non-lawyer representation of corporations is akin to providing legal services to another person, contrary to the Law Society Act. The court also noted that non-lawyers are not subject to the same professional standards or disciplinary consequences as lawyers, nor are they personally liable for costs in the same way as self-represented litigants.

Conduct of the applicant’s representative

The court found that, although Mr. Paraskevopoulos demonstrated a sophisticated understanding of commercial property leases, his conduct in representing the corporation was problematic. He had repeatedly filed factums containing fabricated legal citations, references to non-existent cases, misquoted statutes, and hyperlinks to irrelevant documents. This conduct imposed significant and unacceptable costs on both opposing counsel and the court, who were forced to identify and address these fabrications. The court stressed that a lawyer acting in such a manner would face severe professional consequences, but non-lawyers are not subject to equivalent sanctions.

Outcome and disposition

The court denied leave for Mr. Paraskevopoulos to represent the corporation, citing the risks and burdens his conduct imposed on the legal process. As a result, the corporation’s motion for an extension of time to perfect the appeal was adjourned. The court ordered that if the corporation did not file a Notice of Appointment of Lawyer within 30 days, the registrar would dismiss both the motion for an extension of time and the appeal itself. Additionally, the responding party, 2004424 Ontario Inc., was awarded costs of $5,000 inclusive of HST and disbursements, payable by Stile Carpentry Ltd., reflecting the court’s disapproval of the applicant’s representative’s conduct and the unnecessary costs incurred.