Christine Chui and Anna Fay are former business partners of a successful modelling agency called 'Bling Me'. In or about January 2022, following a break down of their friendship, Christine and Anna decided to end their business relationship. A written agreement was entered into on 1 March 2022 whereby it was agreed that Christine would buy out Anna's interest in Bling Me for the amount of $5 million. The value of Bling Me was assessed by way of 3 different valuations.The written agreement contained a restraint of trade clause which precluded Anna from:

1. setting up, or working in a modelling agency for a period of 2 years from the date of the agreement ("the restraint period").
2. attempting to contact or enter, or entering into, contracts with existing clients of Bling Me (directly or indirectly), for a period of 1 year post the restraint period.

The terms of the written agreement were performed and Christine transferred the $5 million to Anna on 1 June 2022.

On 1 January 2023 Christine became aware that Anna had set up a talent agency business called, "Bellas." Christine was also informed by some clients that Anna had approached them by email regarding moving agencies. Christine also became aware that some of her clients had not renewed their contracts with Bling Me and were now clients of Bellas. As a result, Bling Me's estimated loss of revenue was significant according to the financial records prepared by Bling Me's accountant

Christine commenced proceedings in the Supreme Court of the Northern Territory seeking orders to enforce the restraint of trade clause and seeking damages against Anna for breach of contract.

Anna asserts that Bellas is not a modelling agency but rather a talentagency and therefore she is not in breach of her contract.

1. Prior to the commencement of proceedings, the parties participated in the PD6 of 2009 process.

What categories of essential documents should have been exchanged?

1. During the proceedings, the Associate Judge agrees to make an order for discovery in accordance with the Supreme Court Rules as the parties are dissatisfied with the exchange of documents during the PD 6 of 2009 process. Anna's List of Documents doesn't include any of the documents relevant to Bellas client contracts, Bellas profits or any correspondence with Bling Me's clients. Explain what steps are open to Christine pursuant to the Supreme Court Rules to seek discovery of the relevant documents.

1. Draft an application for further and better discovery together with the supporting affidavit you consider necessary to succeed on this application.