The Queen's Bench Rules suggest the Plaintiff must serve an Affidavit of Documents on the parties 30 days after the last Defense is filed. The Defendant then must serve their Affidavit of Documents 30 days after they have received the Plaintiff's Affidavit. However, it is quite common that parties do not exchange Affidavits of Documents until after mandatory mediation is completed.

Parties are obligated to disclose all documents relevant to any matter in issue in the Action. The form for this has three different schedules. Schedule 1 lists all relevant and material documents in the party's control, custody, or possession for which they have no objection to produce. Schedule 2 lists all relevant documents of which there is an objection to produce, such as those documents which contain solicitor and client privilege. Schedule 3 lists all relevant documents that were previously in possession or control of the party and requires the document's description, the date they were last in control of the party, the manner the document ceased to be in their control, and the present location of the document.

After this, parties will arrange a Questioning, otherwise known as a discovery or deposition. At this stage lawyers will be able to ask questions of the parties to allow them to discover all the relevant facts and evidence of the other party. If a party does not know of an answer to a question, the lawyer may ask a party to undertake to provide them with the answer.