“The only issue before the court was the quantum of child support. Four judges made six different orders that the appellant produce specific financial documentation. He was regularly in breach of these orders and received multiple warnings that his pleadings would be struck. As the motion judge said in her reasons, he had been recently warned that “this was his last chance”.
The remedy was not excessive. Financial disclosure in a family law case is – without doubt – one of the most important obligations. It should be automatic without the need for court intervention. This action was started in 2012. The appellant breached six orders. This court has upheld the use of r.1(8)c of the Family Law Rules, O. Reg. 114/99, in similar circumstances: Roberts v. Roberts, 2015 ONCA 450, 65 R.F.L. (7d) 6; Manchanda v. Thethi, 2016 ONCA 909, 84 R.F.L. (7d) 374, leave to appeal refused, [2017] S.C.C.A. No. 29; Peerenboom v. Peerenboom, 2020 ONCA 240, 446 D.L.R. (4d) 418.”