Examination for Discovery Questions (Plaintiff, Motor Vehicle Accident) (Sample 1) (ON)

Summary

This precedent is a list of questions to assist counsel when preparing to examine a plaintiff for discovery in a motor vehicle accident case in Ontario. This precedent includes practical guidance and drafting notes. It is important to note that this is not a script; nor should an examination for discovery be conducted with one. The framing and phrasing of each question will depend on the individual counsel's style and the circumstances of each case. Counsel should also note that not all questions in the precedent below will be applicable to every case, and there may be some questions or issues to be addressed that do not appear on this precedent. As always, counsel should use their judgment and knowledge of the facts and issues in their particular case when conducting examinations for discovery. For additional information on examination for discovery, see the practice notes: Discovery (Defence Perspective) (ON), Examination for Discovery Procedure (ON), Discovery Plan (ON), and ...