here. - Koskie Minsky LLP

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g) HMQ was previously ordered to produce all relevant documents in this action
by June 13, 2011;
h) After failing to do so, HMQ obtained an order extending that time to
November 30, 2011;
i) HMQ produced over 50,000 documents from July 2011 to December 2011;
j) On September 4, 2012, 9 months after the deadline to produce relevant
documents in this action, HMQ advised that it located further relevant
documents;
k) On October 4, 2012 HMQ delivered an additional 1600 documents and
identified a number of categories of documents that HMQ still needed to
review and produce;
l) In addition, as part of its answers to undertakings, the HMQ identified certain
documents, which were not produced on October 4, 2012 and have yet to be
produced to the plaintiffs, a list of which is attached as Schedule “C”;
m) On October 10, 2012 a timetable was set by Justice Archibald, which included,
among other things, a timetable for the delivery of certain of the documents
noted by the HMQ on October 4, 2012;
n) On November 14, 2012 the HMQ, for the first time, advised:
i) that documents relevant to this action were erroneously produced in
McKillop v HMQ (Court File No. CV-10-41191) and Bechard v HMQ
(Court File No. CV-10-117343-00CP) and needed to be produced in
this action; and
ii)
that additional relevant photographs had been located and not yet
produced;