Pursuant to the Rules of Civil Procedure, the parties must exchange affidavits of documents within 10 days of the close of pleadings; however, in practice there is rarely compliance with this rule. The timing of production of affidavits of documents is often decided by agreement through the case management process. The affidavits set out all of the documents which are relevant to the issues in the action and is divided into four schedules. Schedule A is a list of documents which are not privileged, Schedule B is a list of documents over which the party claims privilege,

Schedule C is a list of those documents which may be relevant but are no longer in the control of the party swearing the affidavit, and Schedule D, which is only for simplified procedure, is a list of all witnesses with information relevant to the action.

The parties will receive copies of each other's Schedule A documents and can seek an order for production of another party's Schedule B documents if they believe privilege does not apply.

Once the parties have exchanged affidavits of documents, examination for discovery will occur. Each named party may be questioned by all opposing parties or their counsel to discover all of the facts and evidence the other party has in its possession which is not contained in its documents. They may also ask questions about the documents themselves.

In the case of corporate parties, they must make one person available for discovery but additional witnesses may be discovered either by agreement or with an order of the court.