Affidavi / Guides / Electronic motion record

How to prepare an electronic motion record in Ontario

Updated 18 July 2026 · Ontario Superior Court of Justice, civil motions

Judges read motion records on screens now. A record that would have been fine in a cerlox binding — no working index, no bookmarks, no links — is, on a screen, a record the judge has to scroll through blind. Ontario courts have said plainly that this is not acceptable: in Basaraba v Bridal Image Inc., 2021 ONSC 8038, the absence of hyperlinks was "more than sufficient" on its own to warrant dismissal of the motion. This guide walks through what an electronic motion record must contain and how to assemble one the court can actually use.

What goes in a motion record

Rule 37.10(2) of the Rules of Civil Procedure sets the contents, in consecutively numbered pages, in this order:

• a table of contents describing each document, including each exhibit, by its nature and date;
• a copy of the notice of motion;
• a copy of all affidavits and other material served by any party for use on the motion;
• a list of all relevant transcripts of evidence, and
• a copy of any other material in the court file that is necessary for the hearing.

The responding party may serve a responding motion record where the moving party's record is incomplete. Check the current text of the rule — the point of this guide is the electronic assembly, not a substitute for the rule itself.

What the court expects the PDF to look like

The Superior Court's Consolidated Civil Provincial Practice Direction and its Case Center guides set concrete expectations for the file you upload:

• One PDF per document, uploaded with "Import Bookmarks" checked. PDF bookmarks are retained and navigable in Case Center after upload. Factums and draft orders are the exception — those go up in Word so the court can work with the text.
• No more than 500 pages per uploaded document. The practice direction is explicit: "A document uploaded to Case Center shall not exceed 500 pages." A larger record must be split into volumes.
• A usable index. Every document sits behind a numbered tab; the table of contents lists each document by tab, nature and date; and the index entries are hyperlinked to their tabs. Affidavits with exhibits should be one PDF with internal hyperlinks from each reference to its exhibit — the direction the court gave counsel in Parekh v Schecter, 2022 ONSC 302.
• No password protection. Protected files break Case Center processing.
• Page numbers top-left or top-centre. Case Center stamps its own page numbers in the top and bottom right, so leave those corners alone.
• Text-searchable pages. Scanned exhibits should be OCR'd — a judge (and opposing counsel) must be able to search and copy from the record.

The naming convention

Documents uploaded to Case Center follow the court's naming protocol — document type, party type, party name, and the date created or signed in DD-MMM-YYYY format:

Factum – Applicant – Wong – 21-NOV-2021
Expert Report – Defendant – Loblaws – 13-MAR-2021

Firm-specific naming conventions, abbreviations and file numbers are expressly not allowed in document names. Get this right before upload — renaming inside the portal is a chore.

Step by step

1. Gather and convert. Collect the notice of motion, every affidavit, every exhibit, transcripts and any other material. Convert Word documents to PDF (export, don't "print to PDF" — printing strips hyperlinks). Keep the originals.
2. OCR anything scanned. Every page should carry a text layer before assembly, or search and hyperlinking will silently fail on those pages.
3. Assemble in rule order with tab pages. Notice of motion first, then each affidavit with its exhibits behind it, then transcripts and other material — each top-level document behind its own numbered tab sheet.
4. Build the index. One row per tab: tab number, document description, date, page. The numbers in the index must match the tabs the documents actually sit behind — an index that drifts from the record is worse than no index.
5. Bookmark the structure. A bookmark per tab (and per exhibit under its affidavit), so the Case Center sidebar mirrors the record.
6. Hyperlink both directions. Index rows link to their tabs; each "Exhibit 'A'" reference in an affidavit links to Exhibit A; and a back-link on each exhibit or tab returns the reader to where they were. See the companion guide on hyperlinking an affidavit to its exhibits.
7. Number the pages consecutively — top-left or top-centre, never the right corners.
8. Check the caps, then split if needed. Over 500 pages, break into Volume 1, Volume 2… with continuous numbering and a master index.
9. Name the file per the convention and upload to the correct bundle with "Import Bookmarks" checked.
10. QA pass. Click every link in the uploaded copy. A broken link found by the judge is the impression your motion leads with.

Sources: Rules of Civil Procedure, RRO 1990, Reg 194 (r. 37.10) · Consolidated Civil Provincial Practice Direction · SCJ: How to Organize & Upload Documents · Basaraba v Bridal Image Inc., 2021 ONSC 8038 · Parekh v Schecter, 2022 ONSC 302

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