In Romfo v. 1216393 Ontario Inc., 2007 BCSC 1772, rev’d by 2008 BCCA 179 but not on this point, the court made an award of special costs for non‑disclosure of documents where the defendants failed to produce relevant documents, were late producing others, and produced a representative for discovery who was uncooperative to the point of rendering his examination a complete waste of plaintiff's counsel's time. The court awarded special costs for the document motions and for preparation and conduct of the wasted examination for discovery.
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