This paper sets out four principles for drafting pleadings strategically – pleading particulars; pleading adverse interests; pleading to inform the scope of document production; and pleading to inform the scope of questioning. Applying these principles will help to ensure pleadings adequately present the claim/defence, and obtain the evidence necessary to make one’s case.

This paper was presented at LESA’s Rules of Court 2020 webinar on November 4 & 5, 2020.