What is the state of the law in Ontario regarding the conduct of counsel in an action directing a verdict?

"That the respondent, however, had little confidence that this action directing a verdict was warranted on the evidence then before the court, appears from the fact that he has felt called upon to state in his brief, as proven facts, circumstances of which the court below was not advised, according to the record, and incidents which were not brought out in evidence. This, of course, is reprehensible practice on the part of counsel, and in our consideration of the appeal we have disregarded these statements, covering six or seven pages of respondent's[125 Cal.App.3d 780] brief." (See also, Ivens v. Simon (1963) 212 Cal.App.2d 177, 183, 27 Cal.Rptr. 801.)