(1) A party seeking an order for discovery (other than standard discovery) must identify the following:
(a) any criteria mentioned in rules 20.14 (1) and (2) that should not apply;
(b) any other criteria that should apply;
(c) whether the party seeks the use of categories of documents in the list of documents;
(d) whether discovery should be given in an electronic format;
(e) whether discovery should be given in accordance with a discovery plan.
(2) An application by a party under subrule (1) must be accompanied by the following:
( a) if categories of documents are sought -- a list of the proposed categories; and
(b) if discovery is sought by an electronic format -- the proposed format; and
(c) if a discovery plan is sought to be used -- a draft of the discovery plan.
(3) An application by a party seeking more extensive discovery than is required under rule 20.14 must be accompanied by an affidavit stating why the order should be made.
(4) For this Division:
"category of documents" includes documents, or a bundle of documents, of the same or a similar type of character.
Note A discovery plan is a plan that has regard to the issues in dispute and the likely number, nature and significance of the documents discoverable in relation to those issues -- see the Court's Practice Note CM6, 'Electronic Technology in Litigation'.