Pye Bros. Fuels Ltd. v. Imperial Oil Limited, 2012 ONCA 153, released today, clarifies the purpose of R 30.02 (3):
[9] Rule 30.02(3) is not intended to provide a means to obtain discovery of documents in advance of commencing a separate action relating to coverage or contractual obligations. The purpose of the Rule is to provide a specific and limited exception to the general rule that only relevant documents need be produced. It is to assist the making of informed and sensible decisions by parties involved in litigation in circumstances where recourse may be had to any available insurance money: Sabatino v. Gunning, 50 O.R. (2d) 171 (C.A.).
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