Rob Ford's lawyer says Justice Charles Hackland, the judge who ordered the mayor removed from office, made "several errors of law" reaching his decision in a factum filed in an Ontario divisional court yesterday.

The statement of facts filed prior to a January appeal hearing against the guilty verdict also claims the judge "adopted the wrong approach" by not finding Ford made a simple mistake by speaking and voting on an item in which he had a financial interest at a February council meeting.

Lawyer Alan Lenczner expanded on the foundation of Ford's appeal, which is due to be heard Jan. 7, detailing how by "construing the MCIA [Municipal Conflict of Interest Act] 'strictly'" Hackland "did the opposite of what the law demands."

Lenczner will also try to convince a panel of three judges that council overstepped its bounds by ordering Ford to pay back $3,150 in donations to his private football foundation in the first place. Ford voted to repeal a previous council decision that ordered he pay back the money gathered in part using the city's official letterhead to donors.

According to the document, Ford and his team believe the MCIA "has no application to the circumstances of this case." Another factum from Paul Magder, the Toronto resident who brought the case, is due before Dec. 24.

Chris Bateman is a staff writer at blogTO. Follow him on Twitter at @chrisbateman.

Photo by mikepop2ca from the blogTO Flickr pool.