to make a specific finding of fact as to when a reasonable
person “with the abilities and in the circumstances” of the appellants “first ought to have known of the matters referred to
in clause (a)”.
 As Mancinelli states, at para. 31, where s. 5(1)(b) is in issue in a motion to add a defendant, the motion should not be
dismissed “in the absence of evidence that the plaintiff could have
obtained the requisite information with due diligence . . . such
that there is no issue of credibility or fact warranting a trial or
summary judgment motion” [citations omitted].
 Such evidence was absent here. There was no evidence to
suggest how the potentially relevant information about suspected
diagnoses could reasonably have been obtained before it was in
 Finally, the respondents argue that, at the latest, the
appellants’ claims against them were reasonably discoverable
when the appellants were served with Dr. Barzo’s third party
claim, which set out specific allegations against Dr. Murphy and
Ms. Edwards. The respondents contend that the appellants ought
reasonably to have discovered their claims against the respondents when they obtained this information.
 If this is the case, however, and the claims against the
respondents were reasonably discoverable at or around the time
the third party claim was issued, the claims are not statute-barred. The third party claim was issued on May 13, 2014 and the
motion to add defendants was brought on May 11, 2016, which is
still within the applicable two-year limitation period.
 Accordingly, the appropriate disposition is to permit the
addition of all three respondents to the action, with leave for the
respondents to plead the expiry of the limitation period in their
Conclusion and Disposition
 For these reasons, I would allow the appeal. I would set
aside the order of the motion judge, and order that the appellants
are permitted to join the respondents as defendants to the action,
and that the respondents are at liberty to plead the expiry of the
limitation period as a defence. I would award the appellants costs
of the appeal fixed at $23,000, and of the motion in the Superior
Court fixed at $20,000, both amounts inclusive of disbursements
and HST and payable jointly and severally by the respondents.