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Joint Document Briefs (JDBs): Best Practices in Ontario Litigation

  • Writer: Kristy Mclaren
    Kristy Mclaren
  • Nov 8, 2025
  • 2 min read


Flat-style digital illustration of Kristy, a professional woman with blonde hair and glasses, standing next to text that reads “Joint Document Briefs (JDBs) in Litigation.” The infographic highlights JDBs as a best practice for trial, explaining that they narrow exhibits, reduce paperwork, and keep trials focused.

Hi Everyone, it’s Kristy from Clearly Legal.


Today, I want to talk about Joint Document Briefs (JDBs) and why they matter in litigation.


What is a Joint Document Brief?


A Joint Document Brief, or JDB, is a compilation of documents that all counsel in a case intend to introduce at trial.


Why JDBs are Considered Best Practice

In litigation, keeping a trial focused is critical. Courts want efficiency, and counsel want to avoid wasting time and resources on duplicating documents and putting forward documents with less or no relevance or importance. By cooperating to vet documents together, parties:


  • Reduce the overall volume of paper and PDF pages

  • Narrow exhibits to what is truly necessary

  • Keep trials streamlined and on track

  • Save costs for clients by focusing only on the essential evidence


Interestingly, while JDBs are widely recognized as a best practice, the Rules of Civil Procedure do not specifically require them (or, at least, they don't yet). Despite this, they are often expected by judges because they demonstrate cooperation and efficiency.


Legal Guidance: Bruno v. DaCosta, 2020 ONCA 602

Caselaw has provided direction on creating JDBs. In Bruno v. DaCosta, 2020 ONCA 602, the Ontario Court of Appeal laid out a six-part test that guides counsels on how JDBs should be prepared and used (stay tuned for another blog on that test). This case reinforced the importance of JDBs in promoting fairness and efficiency at trial.


My Experience with Document Briefs

With over 20 years of litigation support experience, I have prepared JDBs as well as document briefs for other purposes, including:

  • File reviews

  • Negotiations

  • Motions and applications

  • Tribunal hearings


My experience means I know how to:

  • Build accurate, well-indexed briefs

  • Eliminate irrelevant or duplicative materials

  • Ensure documents are formatted and presented properly for court use

  • Create an organized structure that allows counsel and judges to find information quickly


Why This Saves You Money

Poorly prepared briefs waste time in court, frustrate judges (which can result in the lawyer being spoken to in court), and can even lead to rejected filings. When you hire someone with my level of skill:

  • You avoid costly mistakes

  • You save time by having documents properly indexed and formatted the first time

  • Your team can focus on strategy instead of paperwork headaches


📩 Let’s Connect — Contact me at kristy@clearlylegal.ca to learn how my skills in building Joint Document Briefs and litigation document management can save you time and money.

 
 
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