In (Div Ct, 2021) the Divisional Court stated that when a court is questioning the integrity of counsel, that counsel has a right to be heard on the issue:
 Where a motion judge or trial judge intends to call into question the integrity of a lawyer with a finding that the lawyer has breached his or her duty to the court, there is a corresponding obligation on the court to provide that lawyer with notice and an opportunity to be heard. This is a rule of fairness. A lawyer’s reputation is something built on years of hard work. A lawyer’s reputation can be lost in mere seconds when someone reads a judge’s reasons that call into question that lawyer’s integrity. We therefore allow the appeal on the basis of a breach of procedural fairness.
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