What is the test for disclosure of portions of a client’s files?

Ontario, Canada

The following excerpt is from Zeitoun v Falconeri, 2016 ONSC 5360 (CanLII):

Counsel in his usual succinct way has set out the pith and substance of his clients’ position that disclosure of portions of the files at this stage is premature and that “the plaintiff’s motion should be dismissed with costs.” “THE LAW 8. If a lawyer receives a direction that he forward the client's file to another lawyer, he is obliged to deliver only those documents that are the property of the client. Internal memos, emails and notes are not the property of the client. Aggio v. Rosenberg, [1981] O.J. No. 2229

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