Under the Queen's Bench Rules, within twenty days of the close of pleadings the parties are supposed to exchange affidavit of documents. This timeline is rarely adhered to in practice. An affidavit of documents sets out all of the documents which are relevant to the issues in the action and it is divided into three schedules. Schedule A contains a list of documents which are relevant and not privileged, Schedule B lists those relevant documents which are privileged, Schedule C lists those relevant documents which are no longer in the control of the party.

The parties will have access to each other's schedule A documents and can seek an order to obtain schedule B documents if privilege has not been properly claimed or grounds exist to override the claim of privilege.

Once documents are exchanged, the parties will engage in examinations for discovery. In this process, each party is questioned by the opposite party's lawyer to discover all of the facts and evidence of the other party relevant to the dispute.