The Appellant, Howard Larocque (“Larocque”), retained the Respondent law firm, Kantor LLP (“Kantor”), through Timothy Louis (“Louis”), an intermediary lawyer in British Columbia, to represent him in litigation against his father. Kantor billed Larocque for its legal services, which accounts were received and paid for personally by Louis on Larocque’s behalf. Larocque subsequently sought review of the accounts, resulting in a decision to reduce the last bill by $3,000, which Larocque appealed.

After summarizing a Review Officer’s authority pursuant to Rule 10.9, 10.10, 10.17, and 10.18, the Court found that the Review Officer erred by failing to determine whether the accounts were “periodic interim” or “periodic final” before reviewing the accounts, because the characterization of the account determines the applicable limitation period. Since the Review Officer did not first determine whether the accounts were periodic interim or periodic final, his review of the reasonableness of the accounts was missing the requisite foundation, and therefore his reasons were insufficiently grounded. The Appellant’s original Application was remitted back to a different Review Officer for review.