The respondent Wing brought a motion seeking an order that Staff of the Ontario Securities Commission make proper and meaningful disclosure by preparing separate disclosure briefs for each category of allegations.
Wing argued that Staff's provision of an electronic database containing over 370,000 records was a 'dump truck' disclosure that failed to meet the Stinchcombe standard.
The Commission dismissed the motion, finding that Staff had met its disclosure obligations by providing a reasonably searchable and accessible database, and that perfect disclosure is not required in complex cases involving large volumes of material.
A related motion for confidentiality was also dismissed as premature.