You may be interested in Enbridge Pipelines Inc. v. BP Canada Energy Company, 2010 ONSC 3796 (CanLII) for a sample discovery agreement endorsed by Cambell J. of the Ontario Superior Court of Justice. His Honour characterizes the action as complex and with “voluminous documentation.” The agreement was negotiated over six meet and confers and looks like it was modeled from the Ontario E-Discovery Implementation Committee model. Campbell J. says, “Not every action will in my view require the detailed type of plan as set out in this Agreement. Many different types of action need only an informal agreement between counsel.”