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On the hearing of a motion to determine whether a question on a discovery was proper or not, name one important thing to have before

On the hearing of a motion to determine whether a question on a discovery was proper or not, name one important thing to have before the judge by way of evidence.

Hi. Can't figure out what the one important thing is, need help.

Jurisdiction: Canada, Ontario

Resource: Civil Litigation - Revised Fourth Edition - Emond

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