“In Liddell-MacInnis v. MacInnis, 2021 ONSC 1787, at paragraphs 65 – 68, Kraft, J. summarized the general principles that apply on motions for temporary spousal support as follows:
a) The party claiming temporary spousal support has the onus of establishing that there is a triable (prima facie) case, both with respect to entitlement and quantum. The merits of the case in its entirety are to be dealt with at trial.
b) In the event that a spousal support claimant cannot establish an arguable case for entitlement to spousal support, the motion for temporary relief should be dismissed, even if the claimant need and the other party has the ability to pay.
c) The court is not required to carry out a complete and detailed inquiry into all aspects and details of the case, or to determine the extent to which either party suffered economic advantage or disadvantage as a result of the relationship or its breakdown. That task is for the trial judge.
d) The primary goal of interim spousal support is to provide income for a dependent spouse from the time the proceedings are commenced until the trial. Interim support is meant to be in the nature of a “holding order” to, insomuch as possible, maintain the accustomed lifestyle pending trial.
e) Assuming that a triable case exists, interim support is to be based primarily on the motion judge’s assessment of the parties’ means and needs. The objective of encouraging self-sufficiency is of less importance.
f) The Spousal Support Advisory Guidelines is a non-binding guideline that provides a “valuable litmus test” for assessing both the range within which spousal support, or final, should be ordered and the duration of such support.”