PRACTICE AND PROCEDURE - notice to produce documents in affidavit - whether documents are "mentioned" in the affidavit - whether the documents have an apparent relevant to the questions in issue
PRACTICE AND PROCEDURE - notice to produce - where party seeks documents produced on discovery in unredacted form - where an agreed discovery protocol provides that a party is entitled to redact documents on the basis of relevance and confidentiality - whether there is reason to go behind the agreement
PRACTICE AND PROCEDURE - notice to produce - documents redacted for confidentiality - whether claims can be sustained
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