The defendant appealed a master’s order refusing to compel answers to discovery refusals and production of additional financial documents in a fatal motor vehicle accident action involving dependency claims under the Family Law Act.
The appeal challenged the master’s refusal to require the surviving spouse to answer questions about post‑accident income and dividends and to produce corporate and financial documents sought by the defendant’s expert.
The court held that the master applied the correct relevance test and did not commit a palpable and overriding error in determining that questions relating to post‑accident investment income were irrelevant to the dependency claim in the circumstances of a single‑income household.
The court also upheld the master’s discretionary decision to deny several production requests as premature or unnecessary, particularly where the materials had not been pursued during discovery or involved non‑parties.
The appeal was dismissed and the discovery rulings were upheld.