(1)Every document which relates to a matter in issue in an action and which is or has been in the possession or control of a party or which the party believes to be in the possession, custody or control of some person not a party, shall be disclosed as provided in this rule, whether or not privilege is claimed in respect of that document.

(2)Every document which relates to a matter in issue in an action and which is in the possession or control of a party to the action, shall be produced for inspection if requested, as provided in this rule, unless privilege is claimed in respect of that document.

(3)Within 10 days after the close of pleadings, each party shall disclose by letter to all parties adverse in interest and shall produce for inspection, if requested, any insurance policy under which an insurer may be liable to satisfy part or all of any judgment which may be obtained in the action, or to indemnify or reimburse any party for money paid by him in satisfaction of the judgment, but information concerning such insurance policy shall not be admissible in evidence at the trial unless it is relevant to an issue in the action.

(1)A party may serve on any other party a Notice Requiring Affidavit of Documents (Form 31A).

(2)Within 10 days after receipt of a Notice Requiring Affidavit of Documents a party shall file and serve on every other party an Affidavit of Documents (Form 31B).

(3)The Affidavit of Documents shall be made by the party or, in the case of a corporation, by an officer, director or employee.

(4)The Affidavit of Documents shall contain

(5)The Affidavit of Documents shall provide a description sufficient for identification of each document, or, in the case of bundles of documents of the same nature, of each bundle.

(6)The solicitor for a party making an Affidavit of Documents shall endorse it with a certificate that he has explained to the deponent the necessity of making a full disclosure of all relevant documents and that he has no knowledge of any other document which should have been disclosed.

(1)A party is entitled, at any time, to request inspection of any document in the possession or control of any other party which

(2)A party who wishes to inspect a document shall serve on the other party a Request to Inspect Documents (Form 31C).

(3)A party upon whom a Request to Inspect Documents is served shall forthwith serve on the party making such request, a notice stating a time between 9:30 a.m. and 4:30 p.m. and a date within 5 days from the service of the Request to Inspect Documents on which the documents may be inspected at the office of his solicitor or some other convenient place, and shall make the documents available for inspection at that time and place.

(4)A court may, at any time, order production for inspection of documents generally or of any particular documents in the possession or control of a party for which no privilege is claimed. Where privilege is claimed for a document, the court may inspect the document to determine the validity of such claim.

(5)Where a document is produced for inspection, the party inspecting the document is entitled to make a copy at his own expense unless the person having possession or control of the document agrees to make a copy for the party inspecting the document, in which case he shall be reimbursed for the cost of so doing.

(6)Where a document may become relevant only after the determination of one or more of the issues in the action and the production of such document for inspection prior to that determination would result in a serious prejudice to a party, he may apply to the court for leave to withhold the production until after such determination.

(1)The disclosure, or the production for inspection, of a document is not an admission of its admissibility.

(2)Unless the parties agree otherwise, a document listed in an Affidavit of Documents or produced for inspection by a party shall, without notice, summons or order, be taken by him to his examination for discovery and to the trial of the action and shall there be produced upon demand by any party.

(1)Where a party fails to disclose a document in his Affidavit of Documents or fails to produce a document for inspection in compliance with this rule or an order made thereunder, he may not use such document at the trial, except by leave of the trial judge.

(2)Where a party fails to file and serve an Affidavit of Documents or disclose a document or produce a document for inspection in compliance with this rule, or fails to comply with an order made under this rule, the court may

(1)A party may request any other party to admit

(2)Where practicable, a copy of any document referred to in a Request to Admit Document shall be served with it unless a copy is already in possession of the party served.

(3)party upon whom a Request to Admit Documents is served shall be deemed to admit as requested unless, within 10 days thereafter, he serves Notice of Refusal to Admit Documents (Form 31E).

(4)Where the authenticity, dispatch or receipt of a document is admitted or deemed to be admitted by a party, he may not put the admissions in issue, without leave of the court.

(1)Where a document is in the possession or control of a person not a party to the action, any party may apply to the court, on notice to such person and to every other party, for an order for the production for inspection of such document if it is not privileged.

(2)The court may order a corporate party to the action to disclose all documents which are in the possession or control of a subsidiary or affiliated corporation, and which relate to a matter in issue, and to produce for inspection all such documents which are not privileged.

(3)No order shall be made under this subrule for the production for inspection of a document unless the court is satisfied that the document relates to a material issue in the action and that it would be inequitable to require the applicant to proceed to trial without having discovery of that document.

(4)On an application under this subrule, where