“In Zagdanski v. Zagdanski, 2001 CanLII 27981 (ONSC), the court ordered an advance on equalization in the amount of $700,000 to the wife on a motion for partial summary judgment. In doing so, the court set out certain parameters for making such an order. They include (my summary):
a. There will be little or no chance that the amount of the advance will exceed the final equalization amount;
b. There will be a degree of certainty about the right to an equalization payment and the minimum amount;
c. There is a reasonable requirement for funds in advance of any final determination of the case, and;
d. Fairness, prejudice or delay require that such a payment be made.”