What is the burden of producing an affidavit of documents?

The party seeking any further and better affidavit of documents has the burden of proving that the documents being requested exist, are relevant, and that production meets the proportionality requirements set out in rule 29.2.03: Galea v. Best Water Limited, 2019 ONSC 7213, at para. 15, Sarta, at para. 5. Rule 29.2.03 directs the court, when determining whether a party must produce a document, to consider factors including whether the time required to produce the document would be unreasonable, whether the expense associated with production would be unjustified, and whether requiring production would unduly interfere with the orderly progress of the action.