Date: 2012-03-12 Davies J. | Link
Review of a Master's refusal to order productions of the plaintiff's MSP records under R. 7-1(18) in a motor vehicle injury case. " If what was challenged by the defendant was whether the plaintiff’s MSP records were “additional documents” that should be disclosed, the demand for production ought to have been made under Rule 7-1(11), and the application for production should have been made under Rule 7-1(14) where questions of whether the court should alter the test of relevance for document disclosure purposes and if so to what extent, could be addressed. That inquiry would include principles of proportionality."