Rule 222 UCPR requires a clear and unambiguous reference to a specific document in an affidavit before a notice to produce can operate; general references to 'instructions' that do not identify specific documents are insufficient. Where an admission in a pleading is shown to have been included by a production error in the drafting process, the case for leave to withdraw under r 188 is strong, particularly where there is no specific prejudice beyond delay.
The full text is available to signed-in members, including the 6 later cases that cite this judgment.