What is the impact of an amended pleading in a civil action alleging that a defendant failed to supervise and ensure compliance with regulatory standards?

I accept that there is a reasonable likelihood that a trial judge will be of the view that similar fact evidence of any failure on the part of the defendant “to supervise and ensure compliance of its employees” is important and relevant as evidence that could corroborate the plaintiff’s evidence (Mackenzie, supra). I am not satisfied that any added complexity arising from the amended pleading outweighs the potential probative value of the evidence that would be adduced as a result (Garwood Financial, supra); it is reasonable to assume that the defendant will know of and have readily available records of any of its other employees who may have been investigated by the O.S.C. as a consequence of a failure to comply with regulatory standards. Given the potential relevance of the similar fact evidence that the plaintiff seeks to adduce, the pleading that puts that evidence in issue is not scandalous or vexatious (A.G. Ontario v. Dieleman, supra).