Too often parties take a casual approach to compliance with costs orders. I agree with the following passage from Gordon v. Starr, at para. 23: Subrule 14(23) should not be taken lightly. It means what it says. It recognizes the offensiveness of allowing a party to obtain relief while in breach of a court order. Court orders are not made a form of judicial exercise. An order is an order, not a suggestion. Non-compliances must have consequences. One of the reasons that many family proceedings degenerate into an expensive merry-go-round is the all too common casual approach to compliance with court orders. [page795]
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