The Court set aside two categories of a notice to produce seeking 'documents recording assets and/or liabilities' and documents 'in relation to any trust' as too vague, non-specific, and unduly burdensome, while upholding categories seeking financial statements, tax returns, management accounts, and bank statements as sufficiently clear and not onerous. The Court also held that a significant increase in anticipated defence costs since a prior refused security for costs application constituted a sufficient change in circumstances to support a renewed application, providing a legitimate forensic purpose for the notices to produce.
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