“Several Ontario cases speak to surreptitious recordings by parents in family law proceedings creating opportunities for further conflict and mistrust. They cite strong policy arguments against admitting surreptitious recordings into evidence. They have been fully set out by Kurz J. in Van Ruyvern v. Van Ruyven, 2021 ONSC 5963, 62 RFL (8th) 451, at paras. 30 to 43. In this case, the parties will have years to co-parent L together and do not need ammunition to fuel further distrust. As stated aptly by Kurz J. at para. 40 in Van Ruyvern,
…routinely allowing our courts to reward a party’s attempt to secretly spy on the other by admitting the fruits of that conduct into evidence contributes to the corrosiveness of matrimonial litigation. That approach must be discouraged.”