“Turning to spousal support, there is a heavy onus on the party that seeks to vary a temporary spousal support order. Chappel J. summarized the test in Damaschin-Zamfirescu v. Damaschin-Zamfirescu, 2012 ONSC 6689 at para. 20:
The test that applies on a Motion to vary a temporary spousal support order has evolved within the parameters of the general principle that parties in matrimonial proceedings should be encouraged to advance their case to trial as soon as possible. Using this foundational principle, the Ontario Court of Appeal determined in Lipson v. Lipson [1972 CanLII 470 (ON CA), [1972] 3 O.R. 403-404] that proceedings to vary interim support orders should not be encouraged. It held that in order to succeed on a Motion to change a temporary spousal support order, a party must establish that there has been a substantial change in circumstances since the previous temporary order was made. Variation proceedings relating to temporary orders should not become the focus of the parties’ litigation. The onus on a party who seeks to vary a temporary spousal support order rather than waiting until trial is a heavy one.
This test has been applied consistently by the court: Oxley v. Oxley, 2010 ONSC 1609, at para. 26; Biddle v. Biddle, [2005] O.J. No. 737 at para. 18; Boissy v. Boissy, [2008] O.J. No. 2783 at para. 16; Colivas v. Colivas, 2016 ONSC 715 at para. 26.”