Is there a need for a second defence medical?

A need for a second defence medical may be justified where there is an unexpected change in the plaintiff’s complaints, symptoms or circumstances. A further defence medical will not be permitted where the recent disclosure is more a continuation of what was known rather than an unexpected change in complaints, symptoms or circumstances: Fromm v. Rajani, [2009] O.J. No. 3671 (S.C.J.) at paras. 13, 16.