“I find no fault with the trial judge’s refusal to admit the report on the basis of (1) its frailties, and (2) the fact that its value – to impeach the report of the court-appointed expert – remained available to the appellant through cross-examination and, ultimately, argument. I strongly support the view expressed by Justice Wein in Mayfield v. Mayfield(2001), 2001 CanLII 28213 (ON SC), 18 R.F.L. (5th) 328, at para. 44 (Ont. S.C.), that
in most cases, it is simply not necessary or appropriate to have the parties bring forward the evidence of a collateral critique. A social work critique may of course be done to assist counsel in formulating questions for cross-examination of the assessor or to assist counsel in developing an argument concerning the weight to be attached to an assessment report but it will rarely be “necessary” to introduce the critique as original evidence or to call the critique as a witness. The expense in most cases could be better spared or applied to an independent assessment.”