You are the owner of a small movie theatre in Ontario, One evening, a guest slips and falls while walking to their seat. The guest is helped up by one of your employees and despite appearing to be okay, insists that your employee call an ambulance. The guest is taken by ambulance to the hospital. Some months later, this guest sues your business for $400,000, alleging that he fell on some buttery substance on the floor of the theatre and suffered a traumatic brain injury. You immediately meet with a lawyer to discuss the case. As a result of that meeting, the lawyer sends you a letter enclosing a draft defense and setting out their legal opinion about the claim.

Question

As a well-informed business owner, you understand that documentation is an essential part of any risk management strategy. What kinds of documents would you have on hand to provide to your lawyer to assist in the defense of this claim? Be specific in your description of these documents. Based on the facts outlined above, are there any documents that would not need to be disclosed to the other side (i.e., the guest's lawyer)? Explain why or why not.