Affidavi / Guides / Affidavit of Documents
The Affidavit of Documents (Form 30A), step by step
Rule 30.03 requires a party to an action to serve an affidavit of documents — for an individual party, Form 30A — disclosing, to the full extent of the party's knowledge, information and belief, every document relevant to any matter in issue that is or has been in the party's possession, control or power. The affidavit is sworn; getting its structure right is not optional formatting, it is the disclosure obligation itself.
The three schedules
| Schedule | What it lists | Documents attached? |
|---|---|---|
| A | Documents in the party's possession, control or power that the party does not object to producing. | Yes — these are the productions. |
| B | Documents that are or were in the party's possession, control or power for which privilege is claimed, with the grounds for the claim stated. | No. Listed, never attached. |
| C | Documents formerly in the party's possession, control or power but no longer, with a statement of when and how possession was lost and where the document now is. | No. |
The form also carries the lawyer's certificate: where the party is represented, the lawyer certifies having explained to the deponent the necessity of making full disclosure and what kinds of documents must be disclosed. Disclosure is a continuing obligation — documents found later go up in a supplementary affidavit.
Assembling the productions brief
In practice, the sworn Form 30A travels with a brief of the Schedule A productions, and the schedule doubles as the index:
- Number every Schedule A row and put each document behind a matching numbered tab.
- Describe by nature and date — "Email, J. Smith to R. Lee, 4 June 2022," not "misc. correspondence." The description in the schedule is the description the court and opposing counsel will search by.
- Keep the schedule and the tabs in lockstep. If reordering changes the numbers, the schedule must be renumbered too — an index that drifts from its tabs reads as carelessness in a sworn document.
- Hyperlink it. In the electronic brief, each Schedule A row links to its tab, and each tab carries a link back to the schedule — the same usability expectation the courts apply to motion records.
- Name files with their tab numbers ("01 – Agreement of Purchase and Sale – 15-JAN-2021.pdf") so the folder sorts in schedule order and re-assembly is mechanical.
Common failure modes
- Descriptions in the schedule that don't match the documents behind the tabs (dates especially).
- Duplicate documents listed twice under different descriptions.
- Gaps in tab numbering after a late removal — renumber the schedule, not just the folder.
- A one-file Word affidavit whose backsheet ends up buried mid-brief after exhibits are appended.
- Scanned productions with no text layer — unsearchable disclosure invites a fight about adequacy.
How Affidavi builds it
Affidavi generates the Form 30A (or takes the one you drafted), treats Schedule A as the index, matches numbered files to their tabs, weaves the tabs directly behind Schedule A, links every row to its tab and every tab back to the schedule — and its Schedule B/C handling carries no files at all, so a privileged document cannot ride along. Date disagreements between the draft and a file are flagged, never silently "fixed."
An affidavit of documents that assembles itself.
Generate the Form 30A or bring your own; drop the folder; every row finds its tab. On your computer, never uploaded. Launching soon with a 14-day free trial.
See pricing & get notifiedSources: Rules of Civil Procedure, RRO 1990, Reg 194 (r. 30.03) · Ontario Court Forms — Rules of Civil Procedure (Form 30A)
General information about Ontario procedure, not legal advice. Verify against the current Rules and the forms in force for your matter.