(1) A list of documents must be in accordance with Form 38.
(2) The list must describe:
(a) each category of documents in the party's control sufficiently to identify the category but not necessarily the particular document; and
(b) each document that has been, but is no longer in the party's control, a statement of when the document was last in the party's control and what became of it; and
(c) each document in the party's control for which privilege from production is claimed and the grounds of the privilege.
(3) A party may apply to the Court, before or after the list of documents has been served, for an order:
(a) about the use of categories in the list; or
(b) that a more detailed list of documents be provided; or
(c) that each document in a category be separately described.
(4) The list of documents must be verified by an affidavit sworn in accordance with rule 20.22 .
Note Control is defined in the Dictionary.