He found that it is a common practice for a lawyer to issue a series of interim accounts on a file, followed by a final account when the retainer is complete. He noted that the law has often treated interim accounts as being provisional only. They are not final until the last account is rendered. Relying on Morin , Grant v. Olsson ((1994), 37 C.P.C. (3d) 130 (B.C.S.C.) at paragraph 130, he found that whether an interim account is final, or only an advance billing, is a determination that must be decided on the facts of each case.
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