1162740 Ontario Limited v. Pingue, 2017 ONCA 52:
 In my view, every document or thing put to a witness or to the trial judge as a piece of evidence should be made a numbered or lettered exhibit. I would also add this: although trial judges have discretion in whether to mark as exhibits, out-of -court statements that are used solely to impeach the credibility of a witness, for the same reasons the best practice is to mark such statements as lettered exhibits for identification, if not as numbered exhibits: Ontario Courtroom Procedure, at p. 945-946; and R. v. Betker,  O.J. No. 1578, 115 CCC (3d) 421 at 430 (C.A.).
Of the Law Societies of Upper Canada and Nunavut