Judgments

Decision Information

Decision Content

T-2379-90
Sydney Steel Corporation, a body corporate
(Respondent) (Plaintiff) v.
The Ship "Omisalj", Jugolinija and the Owners, Charterers and all others interested in the ship "Omisalj" (Applicants) (Defendants)
INDEXED AS.' SYDNEY STEEL CORP. V. OMISAL/ (THE) (T.D.)
Trial Division, MacKay J.—Halifax, January 14; Ottawa, January 28, 1992.
Practice — Discovery — Examination for discovery — Examinations for discovery in writing in case arising from maritime collision — Plaintiff's questions about previous acci dents involving Master, subsequent action by owners, whether helm would have responded — Whether proper questions — Test for propriety on discovery whether information solicited may be relevant to matters in issue — Doubt resolved in favour of openness — Prior casualties involving Master not relevant to issue whether accident caused by negligence — May be rele vant to statutory limitation of liability — Evidence of subse quent occurrences not of itself evidence of negligence — May have probative value after other evidence of negligence adduced — Questions at discovery asking for opinion permis sible only if put to expert witness whose expertise in issue — Master not expert witness as term understood and opinion as such not in issue.
This was an application under Rule 466.1(3) to have certain questions in a written examination for discovery struck out.
The principal action arose out of a collision involving the defendant ship at the plaintiff's dock at Sydney, Nova Scotia. Of the questions objected to, one asks about previous accidents involving the Master of the defendant ship, two ask whether the company has since changed its practices or instituted disci plinary action, and two ask the Master whether helm action would have been effective in the minutes preceding the colli sion.
Held, application allowed in part—questions on prior and subsequent occurrences to be answered, opinion questions to be struck.
The standard for propriety of questions on discovery is lower than that for admissibility of evidence at trial. It is whether the information sought by the question may be rele vant to any matters in issue in the state of the pleadings at dis covery. Where there is doubt, it will be resolved in favour of the goal of openness. The question about previous casualties involving the Master of the defendant ship is not relevant to the issue of negligence on the occasion in question; but knowl edge by the owners of prior accidents involving their employee would be relevant to their entitlement to limit their liability under section 575 of the Canada Shipping Act. Although the defendants may abandon before trial their claim to limit liabil ity to the amount set out in the Act, which is higher than the likely damages, it is currently part of their pleadings. While evidence of subsequent occurrences is not of itself evidence of negligence, it may have probative value after other evidence of negligence has been adduced. The treatment accorded the answers to these questions at trial is a matter for the trial judge.
The questions as to the likely effect of helm action immedi ately before the collision are put forward as relevant to the expertise and skill of the Master. The Federal Court "opinion question rule" at discovery was stated by the Court of Appeal in Rivtow Straits Ltd. v. B.C. Marine Shipbuilders Ltd.: ques tions asking for the expression of an opinion are not permissi ble unless the witness is an expert whose expertise is put in question by the pleadings. Here, it is the competence of the Master in the particular circumstances which is in question. He is not an expert witness as that term is generally understood, and his opinion as an expert is not put in issue by the plead- ings.
STATUTES AND REGULATIONS JUDICIALLY CONSIDERED
Canada Shipping Act, R.S.C., 1985, c. S-9, s. 575. Federal Court Rules, C.R.C., c. 663, RR. 458(1)(a) (as am. by SOR/90-846, s. 15), 466.1 (as am. idem, s. 16).
CASES JUDICIALLY CONSIDERED APPLIED:
McKeen and Wilson Ltd. v. Gulf of Georgia Towing Co. Ltd. et al., [1965] 2 Ex.C.R. 480; Algoma Central Rail-
way v. Herb Fraser and Associates Ltd. (1988), 66 O.R. (2d) 330; 36 C.P.C. (2d) 8; 31 O.A.C. 287 (Div. Ct.); Rivtow Straits Ltd. v. B.C. Marine Shipbuilders Ltd., [1977] 1 F.C. 735; (1976), 14 N.R. 314 (C.A.).
DISTINGUISHED:
Simonar et al. v. Braybrook et al. (1989), 76 Sask. R. 206; 33 C.P.C. (2d) 89 (Q.B.); Clif-Den Holdings Ltd. et al. v. Automated Concrete Ltd. et al. (1986), 70 A.R. 327 (Q.B.).
CONSIDERED:
Philips Export B.V. v. Windmere Consumer Products Inc. (1986), 7 C.I.P.R. 147; 8 C.P.R. (3d) 505; 1 F.T.R. 300 (F.C.T.D.); Everest & Jennings Canadian Ltd. v. Invacare Corporation, [1984] 1 F.C. 856; (1984), 79 C.P.R. (2d) 138; 55 N.R. 73 (C.A.); D & L Sales Ltd., carrying on business as Royal Specialty Sales v. Mayda Industries Co. Ltd. (1986), 10 C.P.R. (3d) 131; 4 F.T.R. 77 (F.C.T.D.); Savoie v. Bouchard and Board of Trustees of Hotel-Dieu d'Edmundston (1983), 49 N.B.R. (2d) 424; 129 A.P.R. 424; 26 CCLT 173 (C.A.); Meilleur v. U.N.L-Crete Canada Ltd. (1982), 30 C.P.C. 80 (Ont. H.C.).
REFERRED TO:
Can. Cement Lafarge Ltd. v. Caterpillar Tractor Co. (No.1) (1982), 29 C.P.C. 205 (Ont. H.C.); Canadian Pacific Railway Co. v. City of Calgary (1966), 59 D.L.R. (2d) 642; (1966), 58 W.W.R. 124 (Alta. S.C. App. Div.); Cominco Ltd. v. Phillips Cables Ltd., [1987] 3 W.W.R. 562; (1987), 54 Sask. R. 134; 18 C.P.C. (2d) 165 (C.A.); James et al. v. River East School Division No. 9 et al. (1975), 64 D.L.R. (3d) 338; [1976] 2 W.W.R. 577 (Man. C.A.); Glidden v. Town of Woodstock (1895), 33 N.B.R. 388 (S.C.); R & B Fishing Ltd. et al. v. Canada (1986), 1 F.T.R. 305 (F.C.T.D.); Smith, Kline & French Laborato ries Ltd. et al. v. Attorney-General of Canada (1982), 67 C.P.R. (2d) 103; 29 C.P.C. 117 (F.C.T.D.); Drake v. Overland and Southam Press Ltd. (1979), 19 A.R. 472; 107 D.L.R. (3d) 323; [1980] 2 W.W.R. 193; 12 C.P.C. 303 (C.A.); Opron Construction Co. v. Alberta (1988), 85 A.R. 143; 59 Alta. L.R. (2d) 214 (Q.B.).
COUNSEL:
John D. Murphy, for respondent (plaintiff).
A. William Moreira, for applicants (defendants).
SOLICITORS:
Stewart McKelvey Stirling Scales, Halifax, for respondent (plaintiff).
Daley, Black & Moreira, Halifax, for applicants (defendants).
The following are the reasons for order rendered in English by
MACKAY J.: In this application the defendants seek an order that certain questions contained in a written examination for discovery be struck pursuant to Rule 466.1(3) of the Federal Court Rules [C.R.C., c. 663] as amended by SOR/90-846, section 16. Rule 466.1, as amended in 1990, replaced the rule which for merly provided for interrogatories by authorizing written examination for discovery by means of "one list of concise, separately numbered questions ... for the adverse party to answer" (Rule 466.1(1)) and "[a] person who objects to any question in a written examination may apply to the Court to have it struck out" (Rule 466.1(3)).
The action giving rise to this application arose out of a collision at Sydney harbour, Nova Scotia, on March 21, 1989 when, it is alleged, the defendant vessel, while approaching her berth at Sydney Steel Corporation, struck and damaged a mooring dolphin owned by the plaintiff. The defendants have pleaded in defence the absence of any negligence.
Because distance and other logistic difficulties made oral discovery impractical, the plaintiff on November 21, 1990 served a written examination for discovery pursuant to Rule 466.1. Objection to cer tain questions, not resolved by agreement between counsel for the parties, leads to this application for determination by the Court whether five questions, to which the defendants object, must be answered.
The questions at issue are characterized by counsel for the defendants as dealing with prior occurrences, with subsequent occurrences, and with opinion evi dence, a characterization used by counsel for pur poses of considering this application. It is convenient to deal with the specific questions asked in accord
with this characterization, after dealing with general principles applicable.
Under Rule 458(1)(a) [as am. idem, s. 15]:
Rule 458. (1) A person who is being examined for discovery shall answer, to the best of the person's knowledge, informa tion and belief, any question that
(a) is relevant to any unadmitted allegation of fact in any pleading filed in the action by the party being examined or the examining party; ...
Counsel for the parties are essentially agreed that the standard for propriety of a question asked in discov ery is less strict than the test for admissibility of evi dence at trial and the appropriate standard is whether the information solicited by a question may be rele vant to the matters which at the discovery stage are in issue on the basis of pleadings filed by the parties. As noted by the defendants the test is as set out by Norris D.J.A. in McKeen and Wilson Ltd. v. Gulf of Georgia Towing Co. Ltd. et al., [1965] 2 Ex.C.R. 480, at page 482:
... the questions objected to may raise matters which are rele vant to issues raised on the pleadings. This is all that the defendants are required to show. As to whether or not they are relevant and admissible at the trial is a matter for the learned trial Judge.
That standard underlies the decision of Giles A.S.P., in ordering questions to be answered which were "potentially relevant" in Philips Export B.V. v. Windmere Consumer Products Inc. (1986), 7 C.I.P.R. 147 (F.C.T.D.), at pages 153-155.
The same principle, in relation to documents to be produced on discovery, underlies the decision of the Court of Appeal in Everest & Jennings Canadian Ltd. v. Invacare Corporation, [1984] 1 F.C. 856 (C.A.), allowing an appeal from refusal of the motions judge to order production of the balance of a file that contained a letter produced on discovery. Mr. Justice Urie, speaking for the Court of Appeal, said (at pages 857-858):
We are all of the opinion that the appeal must succeed. By producing Exhibit 7, the respondent acknowledged its rele vancy. The letter does not, in any way, on the plain meaning of the words therein, indicate that it relates only to the invention disclosed, if any, in the patent in suit and does not relate to some other device or devices entirely. It would thus appear that to appreciate the letter's relevancy the file from which it was produced may be equally relevant. The correct test of rele vancy for purposes of discovery was, in our opinion, pro pounded by McEachern C.J. in the case of Boxer and Boxer Holdings Ltd. v. Reesor, et al. (1983), 43 B.C.L.R. 352 (B.C.S.C.), when, at page 359, he said:
It seems to me that the clear right of the plaintiffs to have access to documents which may fairly lead them to a train of inquiry which may directly or indirectly advance their case or damage the defendant's case particularly on the crucial question of one party's version of the agreement being more probably correct than the other, entitles the plaintiffs to suc ceed on some parts of this application.
When produced the documents in the file may assist the appellant in its defence. On the other hand, they may not and may, as the respondent says, be totally irrelevant. In either event, the matter in issue may be more readily resolved at trial although their ultimate relevance and the weight to be attached to them will be matters for the Trial Judge.
It is the plaintiff's submission that all of the ques tions to which objection is taken meet the standard for discovery questions, that is, they may be relevant to matters in issue at this stage on the basis of the pleadings. Further, the plaintiff in written submis sions urged that the standard requires the party objecting to questions to establish that those ques tions cannot possibly be relevant to any fact in issue. In my view, the latter submission goes too far. Rather, when objection is taken that a question is not proper because it is not relevant for reasons given, the party asking the question must satisfy the court that the information it seeks may be relevant to a fact in issue. That standard is not likely to be difficult to meet in light of the goal of openness which the rules seek to foster in pre-trial proceedings, particularly discovery, a goal which is the same whether discov ery be oral or by written questions. Moreover, it is settled that where there is doubt as to whether the question need be answered the benefit of that doubt, in light of the principal goal of openness, favours
requiring the answer to be given: (D & L Sales Ltd., carrying on business as Royal Specialty Sales v. Mayda Industries Co. Ltd. (1986), 10 C.P.R. (3d) 131 (F.C.T.D.), per Madam Justice Reed at page 134).
Prior Occurrences
The defendants object to answering the following question:
Q. 1(g) "[What are] details of any previous casualties involving ships on which you [the master] were in com mand or were the officer of the watch at the relevant time?"
The defendants contend this question seeks infor mation about previous incidents which, it is submit ted, are irrelevant to issues in the action based, as it is, on alleged negligence in the operation of the ves sel in particular circumstances at a particular time and place. The defendants rely upon the decision of Wedge J. in Simonar et al. v. Braybrook et al. (1989), 76 Sask. R. 206 (Q.B.), at page 207, though in my view the questions there at issue were more general than the question of prior occurrences here and were there readily determined to lack relevancy to the . issues.
The plaintiff submits that this question meets the standard for questions in discovery, that is it may be relevant to facts in issue, essentially on two grounds. First, one of the issues, raised by the defence as an alternative to the defence of an absence of negli gence, is a claim to limit liability pursuant to section 575 of the Canada Shipping Act, R.S.C., 1985, c. S-9. The knowledge of the owners of the vessel of any record of prior casualties involving vessels when the Master was in charge would be relevant to any claim they may have to limited liability. This is conceded by counsel for the defendants in oral argument but it is urged the question be considered in a broader con text than that issue since the claim to limit liability may be withdrawn if, as seems likely, any limitation
possible is likely to exceed the damages here claimed.
In that broader context, the plaintiff submits the question is relevant to the competence of the Master, and authorities are cited where questions relating to prior facts were allowed. In Royal Specialty Sales v. Mayda Industries Co. Ltd., supra, a case involving alleged infringement of a copyright design, my col league Madam Justice Reed ordered to be answered questions in discovery concerning prior suits for industrial design infringement. In my view, that deci sion turns on the fact that the defence pleaded inno cent infringement, if any had occurred, a fact in rela tion to which the questions were considered relevant as tending to prove knowledge of the likelihood of some intellectual property right in the design in issue and thus tend to disprove the issue of innocent infringement. In Savoie v. Bouchard and Board of Trustees of Hotel-Dieu d'Edmundston (1983), 49 N.B.R. (2d) 424 (C.A.), a case concerning admissi bility of questions at trial about prior occurrences (and thus implicitly of questions that might be asked in discovery), the questions asked were held admissi ble where they were relevant to one party's testimony of a consistent practice which tended to support a conclusion of an absence of negligence on his part. In Meilleur v. U.N.L-Crete Can. Ltd. (1982), 30 C.P.C. 80 (Ont. H.C.), a case in negligence based upon prod uct liability and alleged failure to adequately label containers, to pack properly, to warn and instruct users, questions about other injuries known to the defendant from use of their product, before or after the accident giving rise to the action, were allowed so far as they concerned prior accidents. In that case, it seems to me, the relevance of the questions related to knowledge of the defendant which would affect the duty owed to prospective users in terms of the spe cific claims of failure to provide proper notice or warning of potential hazards. Finally, in Clif-Den Holdings Ltd. et al. v. Automated Concrete Ltd. et al. (1986), 70 A.R. 327 (Q.B.) the plaintiff's claim was
that one defendant had negligently overfilled propane tanks of another defendant whose truck exploded and destroyed the plaintiff's property. That decision by Master Quinn was based, as he notes, on then Rule 200 of the Alberta Rules [Alberta Rules of Court, Alta Reg. 390/68]. As he said, at page 329:
Strictly speaking, it is true that it is not relevant whether Davis Heater overfilled propane tanks of vehicles owned by a company or person other than Automated. It is even true that overfilling of the Davis Heater vehicle's tanks on other occa sions prior to the accident is not relevant from a strictly logical point of view. Davis Heater may have on occasion overfilled other vehicles and may even have on other occasions overfilled the Automated truck, but that does not necessarily mean it over-filled the Automated truck on the occasion that is central to this litigation.
Rule 200 permits examination for discovery with reference to the knowledge of the examinee "touching the question at issue". This is obviously a much wider latitude than a test based strictly on relevancy.
He then found that questions about any other vehicles being overfilled with propane or about overfilling of the truck in question on previous occasions "touch the question in issue" and were to be answered. In my view that decision turns on the scope accorded to the Alberta rule concerning discovery, a scope said to be wider than the test of relevancy, which is the basis set by Rule 458(1)(a) of this Court.
The plaintiff's submission that the competence of the Master is here in issue is acceptable in so far as that competence is evident from his actions at the time and place of the incident giving rise to this suit. His general competence, as that may be judged from previous incidents in which he may have been involved, may also be relevant, as earlier indicated, in relation to any claim by the owners to limit their liability. But general competence in other situations and circumstances is not relevant to the issue of pos sible negligence in the incident at Sydney Harbour. If this were an action involving loss arising from alleged negligence in the operation of a motor vehi cle, questions of the driver about previous accidents in which he was involved would not be relevant to the issue of negligence in the circumstances giving rise to the claim for loss.
Thus, for the issue of possible negligence in the operation of the vessel in approaching the berth at the Steel Company's pier, the question of previous casu alties involving ships under the Master's direction is irrelevant. Nevertheless, the question may be relevant to knowledge of the ship's owners and to their claim to limit liability which is still at issue on the plead- ings and thus I conclude this question is to be answered.
Subsequent Occurrences
Two questions are objected to on the ground they seek information about events subsequent to the cas ualty giving rise to the action and in the defendants' submission they are irrelevant to the issues. Those questions are:
Q. 2(j) If the above answer was in the affirmative (i.e., were there standing orders?) have such Standing Orders been amended since March 21, 1989? If so, please supply a copy of the amendments.
Q. 3(cc) Has this casualty been the subject of any hearing and/or disciplinary action within the company?
Counsel are agreed there are two lines of authori ties dealing with the propriety of questions on discov ery that relate to events or occurrences subsequent to those giving rise to the action. For the defendants it is urged this Court should follow the line of cases excluding such questions, illustrated by the opinion of White J., dissenting, in Algoma Central Railway v. Herb Fraser and Associates Ltd. (1988), 66 O.R. (2d) 330 (Div. Ct.), at pages 336-342. The exclusion of such questions in discovery and at trial, said to be a traditional approach, is based upon lack of rele vance of the answers to the issue of negligence alleged in the incident, and also on policy grounds that no one should be discouraged from taking steps following an accident, out of an abundance of caution or otherwise, to prevent possible similar occurrences by concern that such action may be taken in evidence to support a finding of negligence. The policy grounds are discounted by the majority decision in Algoma Central Railway, and while it is acknowl edged by Chilcott J. in his decision (at pages 334- 336) for the majority that evidence of subsequent events in the nature of remedial measures adopted after the incident is not in itself relevant to the issue of negligence, it may be relevant to other issues, e.g. knowledge of the dangers and feasibility of precau tionary measures, or to the owner's claim to limit lia bility under the Canada Shipping Act, as in this case. Moreover, as other cases have concluded, while evi dence of subsequent occurrences may not of itself be evidence of negligence it may have probative value after other evidence of negligence has been adduced. (See Can. Cement Lafarge Ltd. v. Caterpillar Tractor Co. (No. 1) (1982), 29 C.P.C. 205 (Ont. H.C.)).
For the plaintiff it is urged that this Court should follow the decision of the majority in Algoma Central Railway which decision acknowledges that in light of conflicting decisions it adopts as law for Ontario a position different from that earlier stated by the prov ince's Court of Appeal, in light of the more recent
trend to open discovery, leaving questions of admis sibility and weight of evidence to be determined by the trial judge. A variety of other authorities reaching a similar decision are cited: for purposes of these rea sons it is sufficient to note that the majority decision in Algoma Central Railway reflects the position ear lier adopted in Alberta (see, Canadian Pacific Rail way Co. v. City of Calgary (1966), 59 D.L.R. (2d) 642 (S.C. App. Div.)), in Saskatchewan (see, Cominco Ltd. v. Phillips Cables Ltd., [1987) 3 W.W.R. 562 (C.A.)), in Manitoba (see, James et al. v. River East School Division No. 9 et al. (1975), 64 D.L.R. (3d) 338 (C.A.)), and possibly in New Bruns- wick (see, Glidden v. Town of Woodstock (1895), 33 N.B.R. 388 (S.C.)).
In my view, the general purpose of the Federal Court Rules, to provide all litigants with full and complete discovery prior to trial and to remove as much uncertainty as possible before trial about the respective positions of the parties, supports the adop tion of the majority view in Algoma Central Railway in relation to questions concerning subsequent occur rences that relate to review or remedial or discipli nary measures undertaken following an incident giv ing rise to the action. Such questions may relate to issues other than negligence in the incident, a matter not readily discernible before discovery, or answers to them may be of probative value following the introduction of other evidence of negligence. I accept the answers are not in themselves evidence of negli gence. Whether they are admissible at trial, for what purposes and with what weight are matters for deter mination of the trial judge.
Thus, I conclude that questions 2(j) and 3(cc), to which objection is taken by the defendants, are to be answered in discovery.
Opinion evidence
The final classification suggested for the questions here in issue is those that seek opinions or qualitative conclusions, here essentially of the Master of the ves sel. In oral argument the defendant describes the questions as inviting mere speculation, if not opin ions. The plaintiff, while contending the questions asked do not seek opinions, urges that if they are so characterized the answers ought to be compelled as exceptions to the general rule about opinion evidence since, it is said, they relate to the expertise, the skill and knowledge, the competence, of the Master.
The questions in issue are:
Q. 3(n) Would any helm action have been effective during that 6' minute period when the engine was stopped?
Q. 3(r) During the 7 minutes from 1118 to 1125, would any helm action have been effective?
As a result of discussions between counsel for the parties ancillary questions have been asked, to which the defendant does not object, namely:
Describe the manner in which the Vessel responded to her helm during that 61 minute period; and
During the 7 minutes from 1118 to 1125 what helm move ments were made and in what manner did the Vessel respond to each?
Nevertheless, the plaintiff still seeks answers to the questions originally asked.
The plaintiff urges that the questions do not seek opinions, that they seek simply factual information, "namely whether the helm of the ship would have responded in certain situations", "not whether the defendant thinks that it would or could have responded". In my view that explanation of the ques tions ignores the manner in which the questions are worded and that the questions do not stipulate the "certain situations" to which, in explanation, the questions are said to relate. Rather the questions as asked seem to me to require the defendants to specu late upon possible actions and the judgment or opin ion of the Master or the defendants as a matter of anticipation as to how the vessel might have
responded to those actions. Moreover, I am not per suaded that the questions should be treated as excep tions to the "opinion question rule" referred to by Pratte J. for the Court of Appeal in Rivtow Straits Ltd. v. B.C. Marine Shipbuilders Ltd., [1977] 1 F.C. 735 who said, in part [at page 736]:
... this Court has decided that questions asking for the expres sion of an opinion were not permissible during an examination for discovery unless, perhaps, the witness is an expert whose expertise is put in issue by the allegation of the pleadings... Whatever be the practice in the courts of the various provinces, I am of opinion that, during an examination for discovery held under the Rules of the Federal Court, questions asking for a mere expression of opinion, if permissible at all, are permissi ble only if they are put to a witness whose expertise is put in issue by the allegation of the pleadings... .
See also Dubé J. in R & B Fishing Ltd. et al. v. Canada (1986), 1 F.T.R. 305 (F.C.T.D.); Addy J. in Smith, Kline & French Laboratories Ltd. et al. v. Attorney-General of Canada (1982), 67 C.P.R. (2d) 103 (F.C.T.D.), at pages 107 and 109.
The plaintiff urges that the exception for questions of opinion which can arise where the expertise of a witness is in issue should apply here, for the compe tence or expertise of the witness, the Master, is in issue on the pleadings, including negligence, alleged in the statement of claim, of those in charge of the vessel or responsible for her navigation, maintenance and management, and also by the allegations in the defence of the vessel's failure to respond to helm suf ficiently quickly, its denial of negligence and its plea of inevitable accident. The competence of the Master in the particular circumstances immediately before and at the time of the casualty is certainly in issue by the allegation of negligence and its denial. However, his general judgment based upon his expertise as a Master in light of his experience, is what the ques- dons asked appear to concern. In my view, that is not in issue here. He is not an expert witness as that term is generally understood. His opinion as such a wit ness is not in issue. In my view the questions as asked seek opinions and are not exceptions to the rule
precluding such questions under the Federal Court Rules. The plaintiff referred to two Alberta cases in which questions relating to competence and to opin ions were ordered to be answered in discovery (see, Drake v. Overland and Southam Press Ltd. (1979), 19 A.R. 472 (C.A.) and Opron Construction Co. v. Alberta (1988), 85 A.R. 143 (Q.B.)). Those cases, determined in relation to Alberta Rules, may indicate wider scope for discovery in relation to opinions sought than exists under the Federal Court Rules.
Thus, it is my conclusion that the defendants are not required to answer questions 3(n) and 3(r) and that the defendants' application to strike these two questions should be allowed.
Summary—Conclusion
In accord with these reasons an order goes directing the defendants to answer questions asked in the plaintiff's written examination for discovery dated November 21, 1991, which questions may be relevant to matters in issue but the answers to those questions may be admissible at trial as shall be deter mined by the trial judge. Questions 3(n) and 3(r) of that written examination for discovery are struck out as questions which the defendants are not required to answer.
Success is thus divided on the defendants' applica tion. Costs shall be in the cause.
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