In Roy v. Krilow the plaintiff's affidavit of documents described the documents upon which privilege was claimed as: Document mechanically numbered 000001 to 0000020" Côté J.A. held that was a sufficient description of the twenty documents upon which privilege was claimed. He said: I do not want to leave the impression that it would be suffice merely to describe privileged papers in a big suit as "5287 sheets numbered in red 1 to 5287". One would expect some kind of identification of bundles in a bigger suit.
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