Examination for Discovery Questions (Plaintiff, Motor Vehicle Accident) (Sample 2) (ON)

Summary

This precedent is a list of questions that can be used by a defence counsel when examining a plaintiff for discovery in a motor vehicle accident claim. This precedent includes practical guidance and drafting notes. The areas covered begin with touching upon the background history of the plaintiff through the incident, injuries and post-incident life. Keep in mind that the questions being asked on an examination for discovery should be relevant to the claims made and relief sought typically as what has been set out in the statement of claim. In most cases, the objective of a discovery is to obtain information on liability and damages in order to properly assess the value of a case, both for settlement and trial purposes. Bearing in mind the rule regarding proportionality, the objective generally should be to obtain all of the necessary and important documents first and foremost that are required in order to properly assess the value of the case and hopefully resolve the matter. For ...