Popov concerned possible breaches of contract and fraud; the plaintiffs alleged they loaned money to a company on the basis of fraudulent representations. On behalf of the plaintiffs, Keith Landy brought a motion to require CIBC, who was not a party to the action, to produce certain documents, including bank records. The court granted leave to dispense with service, and ordered that CIBC produce the documents.
https://www.canlii.org/en/on/onsc/doc/2011/2011onsc665/2011onsc665.html?resultIndex=1