What is the test to order the examination of a second representative of a corporate party?

The test to be applied as to whether the court will order the examination of a second representative of a corporate party is, in my view, best stated by Swinton J. in Baylis Estate v. Attorney-General of Canada (2000) O.J. No. 2531 (S.C.J.) at paragraph 9: For an examination of an additional representative of a corporation to be ordered, the moving party must demonstrate that it can not otherwise obtain the discovery to which it is entitled. One of the purposes of a discovery is to obtain information about the case to be met. A second is to obtain admissions from the opposing party. The fact that the person whom the moving party seeks to examine may be an important witness at trial is not sufficient grounds for ordering an additional examination. It is only where the representative can not or will not satisfactorily inform himself that an additional representative will be ordered to be produced.