R v Jalili, 2018 ONSC 6408 (Ahktar):

[53] The test for disclosure can be found at p. 339 of Stinchcombe which states that the Crown need not produce “what is clearly irrelevant”. Communications between the officer in charge dealing with attendance at court, scheduling interviews, and explaining court procedure are therefore not disclosable because they have nothing to do with investigating the allegations.

[54] In R. v. Flis (2006), 205 C.C.C. (3d) 384 (Ont. C.A.), the Court of Appeal considered a defence request to
disclose notes made by police during two pre-charge meetings that the victim and his family attended with the police and the Crown. The Crown argued that the notes were not disclosable as they did not involve discussions of the evidence and were not investigative in nature. The Court of Appeal agreed, stating that the Crown had no obligation to disclose irrelevant notes.

[55] Mr. Thorning’s position that it was incumbent on the police to record every interaction with
the complainant as part of disclosure, is also incorrect.

[56] In R. v. Machado, 2010 ONSC 277, 92 M.V.R. (5th) 58, at para. 121, Durno J. commented that “[w]hile officers’ notes are provided as part of disclosure, there is no law that I am aware of that an officer must record everything he or she did or saw in their notebook to comply with the Crown’s disclosure obligation.” See also: R. v. Whitton, 2016 BCSC 1799, at para. 40; R. v. Antoniak, [2007] O.J. No. 4816, at paras. 24-25.