Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 233 Client means a person who: • Consults a lawyer and on whose behalf the lawyer renders or agrees to render legal services; or • Having consulted the lawyer, reasonably concludes that the lawyer has agreed to render legal services on his or her behalf; and includes a client of the law firm of which the lawyer is a partner or associate, whether or not the lawyer handles the client’s work.785 This provision ensures that a local authority, as the client, has the same protection for its legal documents as persons in the private sector. Whether a solicitor-client relationship exists is a fact driven and multifaceted analysis. Sometimes, it will be readily apparent that a retainer exists. Other times, a careful examination of the facts must be undertaken.786 It is not necessary that a person formally retain a lawyer by way of letter or other document before a solicitor-client relationship can be found. Nor is it necessary that an account be rendered by the lawyer or that an account be paid. There are certain indicia that may or may not determine that such a relationship exists. These include: • A contract or retainer. • A file opened by the lawyer. • Meetings between the lawyer and the party. • Correspondence between the lawyer and the party. • A bill rendered by the lawyer to the party. • A bill paid by the party. • Instructions given by the party to the lawyer. • The lawyer acting on the instructions given. • Statements made by the lawyer that the lawyer is acting for the party. • A reasonable expectation by the party about the lawyer's role. • Legal advice given. • Any legal documents created for the party.787 The client can be an individual, corporation, or local authority. 785 Law Society of Saskatchewan, Code of Professional Conduct at p. 10, Definitions. 786 Trillium Motor World Ltd. v. General Motors of Canada Limited¸2015 ONSC 3824 (CanLII) at [417]. 787 Jeffers v. Calico Compression Systems, 2002 ABQB 72 (CanLII) at [8].
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