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722 - CPC Networks Corp. v McDougall Gauley LLP, Lawyer File Ownership and Production Obligations
07/16/2025
722 - CPC Networks Corp. v McDougall Gauley LLP, Lawyer File Ownership and Production Obligations
This week on Hull on Estates, Stuart Clark and Grey Tiansheng Wen discuss the Saskatchewan Court of Appeal’s recent decision in CPC Networks Corp. v McDougall Gauley LLP, 2023 SKCA 90, a case with significant implications for lawyer file ownership and production obligations. The decision explores what portions of a lawyer’s file belong to the client versus what remains the property of the law firm, and how that distinction impacts disclosure—particularly when former clients request their full legal file or where litigation is ongoing. Stuart and Grey examine the Court’s clarification of key legal principles, including: The distinction between documents prepared for the client’s benefit and those created solely for internal firm use; The burden on lawyers to identify and justify withheld materials; And the recognition that document ownership does not necessarily determine production obligations in discovery. CPC Networks Corp. v McDougall Gauley LLP, 2023 SKCA 90 (CanLII), <>.
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