By Nikolay Chsherbinin ( March 6, 2023, 11:57 AM EST) -- In Ontario, Rule 29.1 of the Rules of Civil Procedure (Rules) imposes an obligation on litigation counsel to meet, confer and to create a written discovery plan before documentary production and discovery get underway. In context of litigation, discovery planning represents the first real opportunity for counsel to work co-operatively together to map out the most efficient and effective way to organize the production and discovery needs of the particular action, having regard to the complexity of the records, the issues in dispute and the amounts at stake....