As noted in Colucci (at para. 48), and countless other decisions before it, timely and full disclosure is one of the core underpinning principles of family law litigation. The court should not step in to make disclosure orders for the most basic financial disclosure, particularly when the moving party seeks relief from a prior court order. This behaviour cannot be condoned or sanctioned by the court. As noted in Roberts v. Roberts, 2015 ONCA 450, 65 R.F.L. (7th) 6, at paras. 11-13, financial disclosure should not require court orders to obtain production.
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