What is the current state of the law on ordering reports to be produced from an electronic database?
Ontario, Canada
The following excerpt is from Sirotek v. O’Dea, 2022 ONSC 1529 (CanLII):
See the discussion on ordering reports to be produced from an electronic database in Watt v. Johnson & Johnson, 2015 ONSC 1032. Reports which do not exist need not be included in an affidavit of documents, but it may be that an undertaking may be sought or an order obtained to extract the necessary data.
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