Can a Defendant ask for all facts you know about impairment in a Statement of Claim?

Can-Air Services used the particular example of “tell me all the facts you know about impairment”. That was a reasonably discreet question about a state of affairs that is usually measured by a compendium of fact. Impairment is usually a conclusion reached by a witness based on observations such as the odor of alcohol on the breath, slurred speaking, red eyes, and unsteady gait. It is one of those areas where non-expert opinion evidence is permitted, because it really is just an assessment of numerous observed facts: Graat v. R., 1982 CanLII 33 (SCC), [1982] 2 S.C.R. 819, 144 D.L.R. (3d) 267, 45 N.R. 451. Here the Defendant is perfectly at liberty to ask questions of fact about particular allegations in the Statement of Claim. For example, the Defendant could ask for all the facts known by the officer about the presence of dead grass on the right of way. However to ask a single compendious question about all of the detailed allegations in para. 18 in the Statement of Claim goes too far.