“An order to strike a party’s pleadings is a drastic remedy that should only be granted in exceptional circumstances and when no other remedy would suffice: Chiaramonte v. Chiaramonte, 2013 ONCA 641, para. 31. In determining whether to strike the pleadings of non-complaint party, a court must (i) consider the substantial disclosure already made; (ii) itemize what disclosure the party had failed to provide; (iii) make a finding of willful disobedience of the order; and (iv) consider proportionality: Manchanda v. Thethi, 2016 ONCA 909, para. 31.
In any event, regardless of the complexity of a spouse’s financial situation, a repeated failure to comply with an order compelling financial disclosure may, even if there is partial compliance, amount to a deliberate attempt the to frustrate the determination of a spouse’s claims for support and equalization: Mullins, supra.”