Prior to joining Gardiner Roberts LLP in 1999, I was an
outsource lawyer, providing legal support services to other lawyers
throughout Ontario. Instead of dealing directly with a lawyer's
client, I would only report to the lawyer who had engaged me. Any
legal document that I produced for court would be filed in the name
of the lawyer for whom I worked. In this regard, the lawyer who
engaged me was ultimately responsible for my work product and any
errors that might be contained therein.
The responsibility of a lawyer for the work of a third party
contractor or outsource lawyer was recently commented upon in
Reddy v. Saroya, 2025 ABCA 322.
In this case, the Court of Appeal of Alberta was required to
determine if an order declaring the appellant, S, in civil contempt
for failing to provide adequate responses to several undertakings
should be reversed. To support the appeal, S's lawyer filed a
factum, which had been produced by a third party contractor. The
factum
