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r 13.05

Objections

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Part 13Interrogatories

13.05 Objections

(1) A party may object to answering an interrogatory on any of the following grounds:

(a) the interrogatory does not relate to a question in issue between the parties;

(b)

the interrogatory is unclear, vague or too wide;

(c)

the interrogatory is oppressive;

(d) the interrogatory requires the party to express an opinion that the party is not qualified to give;

(e)

privilege, stating sufficiently the grounds of privilege;

(f)

any other ground on which objection may be taken.

(2) Without limiting subrule (1)(a), an interrogatory that does not relate to a question in issue between the parties includes an interrogatory the sole purpose of which is to:

(a)

impeach the credit of the party being interrogated;

(b) enable the interrogating party to ascertain whether he or she has a claim or defence other than the claim or defence raised in the proceeding; or

(c) enable the interrogating party to ascertain the evidence by which the party being interrogated intends to prove his or her case, including the identity of witnesses.

(3) A party is not entitled to object to answering an interrogatory on the ground that he or she cannot answer without going to a place that is not the party's usual place of residence or business if the interrogating party undertakes to pay the party's reasonable cost of going there, unless the Court orders otherwise.

(4) If a party objects to answering an interrogatory, the party must state the grounds for making the objection and the facts, if applicable, on which the objection is based.

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