Justice Myers, in Manchanda v. Thethi, (2016), made the following observation regarding the obligation to make financial disclosure in a family law proceeding: Early, voluntary, and complete disclosure of financial information is essential to family law proceedings. This has been said and written by judges over and over again. It is the duty of parties to establish their incomes, expenses, assets, and liabilities as at the various valuation dates depending on the specific relief claimed in the proceeding. Even where valuing one’s property may be inconvenient or expensive, the duty to obtain all necessary valuation expertise required to do so lies on the party who owns the particular property.[15]
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