In Aviva Insurance Company of Canada v. Frank McKeown (2016), Aviva brought an application to determine whether an insurer is obligated to state their reason for an examination under oath (EUO) in order to compel a person claiming statutory accident benefits (SABS) to attend an EUO, if requested by their insurer, pursuant to subsection 33 (2) of the SABS. Aviva was seeking a legal order to compel the named respondents to attend their respective EUOs.