Canada Life Mortgage Services Ltd. v. Leeside Estates Ltd.

Canada Life Mortgage Services Ltd. v. Leeside Estates Ltd.

The court refused leave for broad production of banking and CFIA records for lack of exceptional circumstances and tenuous relevance, but found exceptional circumstances and implied waiver/fairness justified limited disclosure of former solicitor Muttart's documents relating to the terms of his retainer and the content and timing of advice relevant to Lee's pleaded defenses and counterclaims, while excluding financial billing details.

Citation
2002 NSSC 30
Parties
Plaintiff/defendant by Counterclaim: Canada Life Mortgage Services Ltd.; Defendants/plaintiffs by Counterclaim: Leeside Estates Ltd. and Byung K. Lee; Defendants by Counterclaim: Canuck Holdings Limited; Canuck Development Services Limited; Bruce Christmas; Andrew Cooke; Defendant by Counterclaim: Canada Mortgage and Housing Corporation
Court
Supreme Court of Nova Scotia
Jurisdiction
Canada
Judgment Date
18 January 2002
Procedural Posture
Mortgage Foreclosure With Counterclaim (contract and Tort Claims) / Interlocutory Application for Production of Documents During Pre Trial Discovery
Outcome
Application partially granted and partially denied
Legal Topics
Discovery Rules, Waiver of Privilege, State of Mind Exception, Negligent Misrepresentation, Breach of Contract, Breach of Fiduciary Duty, Scope of Retainer
Source Language
English

Case Brief

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Parties

Canada Life Mortgage Services Ltd.

Plaintiff/defendant by Counterclaim

Leeside Estates Ltd. and Byung K. Lee

Defendants/plaintiffs by Counterclaim

Canuck Holdings Limited; Canuck Development Services Limited; Bruce Christmas; Andrew Cooke

Defendants by Counterclaim

Canada Mortgage and Housing Corporation

Defendant by Counterclaim

Procedural Posture

Mortgage Foreclosure With Counterclaim (contract and Tort Claims) / Interlocutory Application for Production of Documents During Pre Trial Discovery

  1. 1 Whether leave should be granted under Civil Procedure Rule 28.05(2)-(3) for further interlocutory discovery after notice of trial
  2. 2 Whether the banking and employment/CFIA documents sought were relevant and whether exceptional circumstances existed to justify discovery
  3. 3 Whether solicitor-client privilege over former solicitor Muttart's documents was waived or subject to the state-of-mind exception and thus producible

Ratio Decidendi

The court refused leave for broad production of banking and CFIA records for lack of exceptional circumstances and tenuous relevance, but found exceptional circumstances and implied waiver/fairness justified limited disclosure of former solicitor Muttart's documents relating to the terms of his retainer and the content and timing of advice relevant to Lee's pleaded defenses and counterclaims, while excluding financial billing details.

Court Disposition

Application partially granted and partially denied