In your letter of August 12, you reiterate that a party must disclose documents in its possession that are relevant to the proceedings and are not subject to privilege.
According to that letter, you began gathering documents for the commission around November 2020, right after the commission was created by order in council on October 21.
What is the process for document collection and production?
Do you automatically turn over certain documents to the commission or do they have to be subpoenaed before they are produced?