“Shirley wants Galo to produce “full financial disclosure” from his wife because she believes that Galo’s wife is secretly holding Galo’s assets and is colluding with Galo who is attempting to evade paying spousal support. Shirley also wants all of Galo’s income tax returns and Notice of Assessment from 2004 to date so that she can calculate the annual spousal support increases that were not paid.
The request for extensive disclosure and a valuation is denied. My reasons follow.
The request for this disclosure is premised on mere speculation and is unreasonable.
In his sworn financial statement, Galo disclosed his wife’s income and their equal sharing of expenses. This level of disclosure from a new partner is typically sufficient (as in this case), to address the financial circumstances of a payor or payee, who has a new partner. There is no right to disclosure beyond these essential facts.
A former spouse is not entitled to the “full financial picture” of a spouse’s new partner by right. Such disclosure would be extensive and intrusive. As Justice Kristjanson stated in Politis v. Politis, 2018 ONSC 323 at para. 17:
Compelling the production of personal income, asset and other financial information of new life partners is highly invasive of personal privacy and generally of minimal relevance. The privacy interests of third party new partners must be carefully balanced against the interests of the parties to the family law proceeding, and any production order carefully scrutinized.”