The Court of Appeal refused a pro bono referral under UCPR r 7.36, holding that while both the applicant and the Court would benefit from legal assistance, the interests of the administration of justice did not warrant calling upon limited pro bono resources in circumstances where the self-represented litigant had an adequate command of English, was familiar with the trial record, and the appeal involved a relatively straightforward review of procedural fairness based on the trial transcript. The Court reaffirmed that the mere fact a litigant would be assisted by pro bono representation is insufficient; the Court must consider what the overall administration of justice requires, including the limited nature of pro bono panel resources.
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