SAMPLE ORDER FOR DOCUMENT PRODUCTION BY FULL DISCLOSURE
1. Each party shall give by 4pm on (date) disclosure to every other party.
2. Disclosure shall be given of those documents that:
a. are in the control of that party, and
b. may be used or relied upon and that are relevant to the claims or defences of any party or are relevant to matters otherwise in issue.
3. Disclosure shall be given by listing each document or category or class of documents
4. The list shall identify documents in a convenient order and manner, shall assert any claims to privilege by reference to any category or class of documents, shall state what has become of any documents that a party did have but no longer has control of and shall be signed by or on behalf of the party as complete and correct.
5. Document shall include any medium in which information of any description is recorded.
6. Control shall include physical possession, right to possession, right to inspect or make copies.
7. Relevancy shall include documents that may not be admissible