Question juridique clé
Whether the district judge had to recuse herself because she used knowledge from a parallel case and commented on the appellant's accounts during a reference hearing.
Solution extraite
No objective appearance of bias arose: the judge relied on judicially known facts relevant to the dispute and was allowed to mention their source while preserving the parties' right to be heard.
Motifs extraits
Facts from parallel proceedings within the scope of the dispute may be treated as judicially known facts. Since the appellant had already been held obliged to account and disclose the relevant records, referring to the account did not breach procedural maxims or secrecy and did not create an appearance of partiality.