On appeal, the Appellate Body relied on Rule 16(1) of the "Working Procedures for Appellate Review" to create additional procedures to deal with the "amicus curiae" briefs. Of the 11 briefs submitted, the Appellate Body accepted none on the basis they failed to comply with these additional procedures. In Canadian law, an "amicus curiae" is a lawyer, rather than an outside entity, who is asked by the Court to provide submissions in such a way as to make sure the legal issues affecting the interests of all parties are properly canvassed. Where one of the parties (e.g. the accused in a criminal case) is unrepresented (and is ineligible for or refuses to apply for legal aid), and the judge is concerned that this will leave that party at a significant disadvantage and risk a miscarriage of justice, the judge may appoint a lawyer as "amicus curiae". The lawyer is not retained by and does not represent the unrepresented party as such, but he or she has a responsibility to ensure that points of law of importance to the party's case are brought to the attention of the court. For example, in the case of a criminal trial, the "amicus" will have the responsibility to ensure that the accused's right to make full answer and defence is upheld. Examples of situations that could call for the appointment of "amicus" could include a highly complex or technical trial, an unsophisticated accused or one with cognitive or psychiatric challenges, or an unruly and disruptive accused. In some cases, when an accused has retained counsel for part of the trial but then fires that counsel, and if the judge finds that "amicus" is needed, the former counsel may be asked to remain as "amicus", given his or her familiarity with the case. Another situation in which "amicus" may be appointed is when an accused is self-represented in a trial for offences such as sexual assault or assault in a domestic violence context. An unrepresented accused has the right to cross-examine Crown witnesses, but it may be undesirable to permit him or her to personally cross-examine, for example, the complainant. As a result, the "Criminal Code" permits the judge to order that the accused will not personally cross-examine the witness, and to name an uninvolved lawyer to conduct the cross-examination in place of the accused.