Les Mackoff is a regular contributor to CLE courses. Most recently, Les presented at British Columbia Continuing Legal Education Society’s 2015 Personal Injury Update. Les was asked to discuss the distinction between participant experts and consulting experts which was addressed by the Ontario Court of Appeal in Westerhof v.Gee Estate (2015) OCA 206. In Westerhof the Ontario Court of Appeal fundamentally altered the classification of an expert witnesses based upom whether they participated in the plaintiff’s treatment or were retained strictly to consult as an expert for court purposes. This issue is certain to arise in British Columbia in the near future.