Lipovetsky v. Sun Life Assurance Company of Canada, 2018 ONSC 1649

Prior to examinations for discovery, the Defendant listed three surveillance douments, including the date, author, and recipient, in Schedule “B” of its Affidavit of Documents. The Plaintiff took the position that additional particulars were required including the form of the document, the timing of surveillance sessions, and the number of pages of any report. Master Jolley concluded that the Defendant was required, and had, set out sufficient particulars to comply with the purpose of Schedule “B” and to allow the Plaintiff to challenge the claim for privilege of the documents.