Defendant made extensive efforts to source and disclose electronic and other documentary data sought by plaintiff

Defamation - interlocutory motion - plaintiff's application to strike out defendants' defence for failure to make adequate discovery - O. 31 Rule 21 RSC - orders previously sought and refused by Master of High Court - substantive proceedings concerning alleged defamatory statements made during radio interview in 2012 regarding plaintiff company's safety record - correspondence between parties, and later affidavits from same, evidencing alleged missing, deleted or reconstituted documentation covered by plaintiff's discovery request - steps taken to ascertain electronic data sought - retention and deletion of documents by defendant association addressed on affidavit - test to be applied in application to strike out proceedings - high threshold - whether a willingness to remedy error(s) shown - plaintiff's complaints unjustified on the affidavit evidence presented - level of default not at a level which would warrant an order to strike out -issue of searches of electronic data - 'Good Practice Discovery Guide' - defendant's resourcing facilities not extensive - deleted documents were in hard copy - case will deal with issues of objective facts given the defences as pleaded, 'truth' and 'honest opinion' - costs of discovery to be proportionate to value of documents discovered - very little information actually put, or maintained, in electronic form - steps taken to search defendant's database were reasonable and adequate - reliefs refused.