Far too often disclosure by a party is incomplete. It is helpful to return to Rule 13 (6) which requires a party to “make full and frank disclosure of the party’s financial situation”. In Rizzo v. Rizzo (2001), 2001 CanLII 28119 (ON SC), 14 R.F.L. (5th) 177 (Ont. S.C.J.), Nelson J. at para. 23, referred to this phase as meaning “complete, detailed and timely disclosure”. I agree.
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