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How to choose motion record software in Ontario

Updated 13 September 2026 · A buyer's checklist for litigation practice

Software that builds motion records, affidavits and productions briefs is judged by one thing: whether the file it produces is accepted and usable in court. Everything else — speed, price, polish — comes after that. This checklist is written from the Ontario Superior Court's own expectations for electronic materials, so you can test any product against the rules your record will be judged by, including Affidavi.

1. Does the output match the practice direction?

The Case Center guidance describes usable materials: one PDF per document, text-searchable throughout, bookmarked, hyperlinked from the index and from each exhibit reference, within the page cap per document, and named to the court's convention. Ask for a sample record and check each of those in the finished file — not in a demo, in a PDF you can open. In Basaraba v Bridal Image Inc., 2021 ONSC 8038, missing hyperlinks were reason enough to dismiss a motion; a product that produces links "sometimes" is not producing them.

• Do index entries link to their tabs, and do the tab numbers match the index?
• Does every exhibit reference in an affidavit link to the exhibit, and does the exhibit link back?
• Are there bookmarks for every document and exhibit?
• Does the software OCR scanned pages so they are searchable, and tell you when it could not?
• What happens at the page cap — does it split volumes, or leave you to count?

2. Where are your documents processed?

Many bundling and PDF-linking services upload your documents to their servers, process them there, and send the result back. For a sworn affidavit with a client's financial, medical or corporate records attached, that is a confidentiality question before it is a convenience question: one more place the material is copied, one more entry a breach notification would have to cover, and a term some retainers do not allow. Ask plainly: does the document leave my computer, and if so where does it go and how long is it kept? Software that runs entirely on your own machine answers all three at once.

3. How does it handle exhibits?

The tedious part of an affidavit is the exhibits: lettering them, placing them, making the covers, and doing it all again when one is added in the middle and every later letter shifts. Look for software that reads the exhibit references in the affidavit itself and places the files against them, that flags a doubtful match rather than guessing, and that re-letters and re-links the whole record when it changes.

4. Can it build the Affidavit of Documents?

Discovery productions are a record too: Schedule A of the Form 30A is the index of the productions brief, and every row should link to the document behind its tab. Check whether the product understands the schedule structure, whether it can produce Schedule B and C entries without attaching the privileged documents, and how it treats photographs, native files and oversized documents that cannot sit inside the brief as pages.

5. Is the redaction real?

A redaction that draws a black box over text leaves the text in the file, where a copy-and-paste or a search will find it. Ask how the product removes content, and whether it verifies the finished file by reading it back. A verified redaction names what it checked; an unverified one should never be presented as finished.

6. Is it built for Ontario?

Form 4C backsheets, numbered tabs, the Case Center naming convention and page cap, the Form 30A schedules — the details are provincial. Software built for another jurisdiction's courts may produce a handsome record that still needs rework. Ask which courts and portals it targets and whether the rules are applied automatically or left to you.

7. What does it cost, and on what terms?

• Per computer, per user, or per firm? Can a lawyer use it at the office and at home on one licence?
• Is there a genuine trial of every feature, and does it need a card up front?
• Are the refund and renewal terms published? Automatic renewal must be disclosed before you buy.
• Who is the merchant of record, and where is the receipt issued?

8. Who answers when something goes wrong?

Ask how support is reached and how quickly it answers, whether a support request ever needs you to send a client document, and how updates arrive — silently in the background, or when you ask.

Questions to put to any vendor

1. Show me a finished motion record: open it and click the index and the exhibit links.
2. Does my document ever leave my computer? Where does it go and for how long?
3. What happens when a referenced exhibit has no file, or a file matches no reference?
4. How is a redaction verified?
5. Which courts' filing rules are applied automatically?
6. What are the refund and renewal terms, and where are they written down?

Where Affidavi stands

Affidavi is built around this checklist: the finished record is one hyperlinked, bookmarked PDF with tabs and an index that match; exhibits are lettered and placed from the affidavit's own references, doubtful matches flagged; the Affidavit of Documents uses Schedule A as the index; redactions remove content and are verified by reading the output back; filing profiles apply the caps and naming for 80+ Canadian courts and portals, Ontario first; every document is processed on your own computer; and the refund and renewal terms are published. Plans are on the pricing page with a 14-day free trial of every feature. The same checklist should be run against Affidavi as against anything else — with a real record, in the finished file.

Sources: SCJ: How to Organize & Upload Documents · Consolidated Civil Provincial Practice Direction · Basaraba v Bridal Image Inc., 2021 ONSC 8038 · See also: preparing an electronic motion record · Affidavi vs. Acrobat

General information about Ontario procedure, not legal advice. Verify against the current Rules and the practice direction that applies to your matter.