FORM 30B

AFFIDAVIT OF DOCUMENTS

(CORPORATION OR PARTNERSHIP)

(General Heading — Form 4A)

AFFIDAVIT OF DOCUMENTS

(Recital as in Form 4D)

1.	I am the (state the position held by the deponent in the corporation or partnership) of the plaintiff (or as may be), which is a corporation (or partnership).

2.	I have conducted a diligent search of the corporation's (or partnership's) records and made appropriate enquiries of others to inform myself in order to make this affidavit. This affidavit discloses, to the full extent of my knowledge, information and belief, all documents relating to any matter in issue in this action that are or have been in the possession, control or power of the corporation (or partnership).

3.	I have listed in Schedule A those documents that are in the possession, control or power of the corporation (or partnership) and that it does not object to producing for inspection.

4.	I have listed in Schedule B those documents that are or were in the possession, control or power of the corporation (or partnership) and that it objects to producing because it claims they are privileged, and I have stated in Schedule B the grounds for each such claim.

5.	I have listed in Schedule C those documents that were formerly in the possession, control or power of the corporation (or partnership) but are no longer in its possession, control or power and I have stated in Schedule C when and how it lost possession or control of or power over them and their present location.

6.	The corporation (or partnership) has never had in its possession, control or power any documents relating to any matter in issue in this action other than those listed in Schedules A, B and C.

(SWORN, etc. as in Form 4D)

(signature of deponent)

CERTIFICATE OF LAWYER

I CERTIFY that I have explained to the deponent the necessity of making full disclosure of all relevant documents.

(Date)

(signature of lawyer)

SCHEDULE A

Documents in the corporation's (or partnership's) possession, control or power that it does not object to producing for inspection.

(Number each document consecutively. Set out the nature and date of the document and other particulars sufficient to identify it).

SCHEDULE B

Documents that are or were in the corporation's (or partnership's) possession, control or power that it objects to producing on the grounds of privilege.

(Number each document consecutively. Set out the nature and date of the document and other particulars sufficient to identify it. State the grounds for claiming privilege for each document).

SCHEDULE C

Documents that were formerly in the corporation's (or partnership's) possession, control or power that are no longer in its possession, control or power.

(Number each document consecutively. Set out the nature and date of the document and other particulars sufficient to identify it. State when and how possession or control of or power over each document was lost, and give the present location of each document).