In the case of Schulz v. S.A. Armstrong Ltd dated April 11, 2023, involved the defendant S.A. Armstrong Limited, a privately held Toronto-based company specializing in fluid flow design solutions for various applications, facing a wrongful dismissal claim from the plaintiff, Mr. Schulz, who had been a senior employee and part of the company's leadership team, reporting directly to the CEO. The legal dispute had revolved around the defendant's concerns about the confidentiality of certain documents, both within the plaintiff's and defendant's affidavits of documents, and the potential harm to the defendant's business if those documents were disclosed publicly. During a case conference in May 2022, the defendant had proposed a confidentiality agreement, but the plaintiff rejected it, contending that the defendant was already protected by the deemed undertaking rule. The court had granted the defendant's alternative relief motion, which required the plaintiff to provide 30 days' notice before filing documents designated as confidential by the defendant. Additionally, the court had ruled in favor of the plaintiff's motion, which sought unredacted versions of specific redacted documents produced by the defendant, along with certain document production requests. However, the court had rejected other requests due to their broad or unfocused nature. Finally, concerning costs, the defendant had been awarded costs for both motions due to the plaintiff's refusal to accept the defendant's reasonable proposal for advance notice regarding document filings. The court had ordered the plaintiff to pay the defendant's costs amounting to $7,500 within a 30-day period.