In White v. Meiting, the Supreme Court of Newfoundland and Labrador denied a plaintiff’s application for an advance or periodic payment. In doing so, the court clarified the criteria which must be satisfied by a plaintiff who seeks an advance payment of special damages pursuant to Rule 44A of the Rules of the Supreme Court, 1986. It also considered the circumstances under which a plaintiff may be entitled to a periodic payment under section 26.2 of the Automobile Insurance Act. In its decision, the court agreed with the analysis set forth in Wade v. Bartlett.

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