The Court dismissed a self-represented plaintiff's appeal from a judicial registrar's orders setting aside subpoenas, refusing recusal, and making timetabling directions. The Court confirmed that subpoenas seeking documents about non-parties' medical treatment at other hospitals, and incidents unrelated to the pleaded cause of action, lack legitimate forensic purpose and cannot be sustained as 'propensity' or 'systemic conduct' evidence where the pleading raises only a specific, confined claim against identified defendants. On recusal, the Court applied the three-step Ebner/SunshineLoans framework and held that lodging a complaint against a judicial officer (whether to VEOHRC or the Judicial Commission) cannot, without more, ground apprehended bias, as permitting otherwise would allow litigants to influence the composition of the bench by the mere filing of a complaint.
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