Rule 30.10(1) of the Prince Edward Island Rules of Civil Procedure allows for production of documents in the possession, power or control of non-parties where the document is not privileged and a) the document is relevant to a material issue in the action and b) it would be unfair to require the moving party to proceed to trial without the documents. The rule had never been considered by PEI courts in a written decision until the recent case of McCabe v Wawanesa Mutual Insurance Company [McCabe].