CWB MAXIUM FINANCIAL INC v 2026998 ALBERTA LTD

In the context of an upcoming Summary Trial, the Defendants sought production of the entirety of a document, an extract of which was made an exhibit to a witness’ Affidavit. The Defendants’ position was that attaching an extract rather than the whole document was contrary to Rule 13.21(3).

Justice Mah disagreed. His Lordship concisely remarked that Rule 13.21 does not require that the entirety of any document referred to must be appended as an exhibit. Justice Mah further noted that, in many cases, this would be impractical.