In Berta v. Berta, 2019 ONSC 505, 23 R.F.L. (8th) 201, after reviewing a number of authorities with regard to the test for an interim variation of a final support order, Kurz J. found that the test has included a requirement that the moving party establish a clear case of hardship and urgency. And in Ivens, Kurz J. found that those same two prerequisites also apply to an interim variation of a parenting order.
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