Paragraphs in a factum must be numbered. Each source cited requires a short form citation, which is to be included in parentheses immediately following the relevant text. The complete reference is included at the end of each paragraph, in smaller, indented text, with references listed in the order they appear in the text.
Following the first full citation of each source in the references include the short form citation in brackets. If a reference is repeated, use the short form citation with the word supra (eg., Brown, supra para 2 at para 14). Factums do not use ibid.
Example:
1. The issue at hand pertains to the enforceability of the non-compete clause in the employment contract. To be upheld, a non-compete clause must satisfy the requirements of reasonableness and protectable proprietary interests [Payette]. In assessing reasonableness, Canadian courts consider factors such as the geographic scope, duration, and nature of the restriction [RBC].
Payette v Guay Inc, 2013 SCC 45, para 29 [Payette].
RBC Dominion Securities Inc v Merrill Lynch Canada Inc, [2008] 1 SCR 241, para 30 [RBC].