You should contact the Law Society of Upper Canada and do a formal complaint against the paralegal. They could be reprimanded. This may help your appeal as well as it shows you had poor representation and they were reprimanded. You should have adjourned until she was subpoenaed, he should have told you this. You had poor representation (you know this already) and would have fared better with hiring a "walmart greeter" with no knowledge of the law.