What are the elements of a litigation plan?

The plan falls short of providing essential elements which should be addressed in any litigation plan as outlined by Nordheimer J. in Bellair v. Independent Orders of Foresters (2004), 5 C.P.C. (6th) 64. “(i) the steps that are going to be taken to identify necessary witnesses and to locate them and gather their evidence; (ii) the collection of relevant documents from members of the class as well as others; (iii) the exchange and management of documents produced by all parties; (iv) ongoing reporting to the class; (v) mechanisms for responding to inquiries from class members; (vi) whether the discovery of individuals class members is likely and, if so, the intended process for conducting those discoveries; (vii) the need for experts and, if needed, how those experts are going to be identified and retained; (viii) if individual issues remain after the determination of the common issues, what plan is proposed for resolving those individual issues, and; (ix) a plan for how damages or any other forms of relief are to be assessed or determined after the common issues have been decided.”