“I note that there are strong policy reasons discouraging the use of surreptitiously recorded interactions in family law litigation, except in cases where the probative value of the evidence is compelling: Turk v. Turk, 2015 ONSC 3165 (SCJ). See generally, Martha Shaffer, “Surreptitiously Obtained Electronic Evidence in Seven Simple Steps”, (2019) 38 Canadian Family Law Quarterly 259. Courts have found that the admission of surreptitiously obtained evidence tends to undermine the goals and values of family law, since the violation of privacy inherent in these acts is more likely to increase conflict and to reduce the prospect that the parties will be able to work together in the future: DeGiorgio v. DeGiorgio, 2020 ONSC 1674 at para 12. Courts have also found that admitting evidence obtained through surreptitious practices sends the wrong message by appearing to reward the behavior, whereas such practices should be discouraged: Seddon v. Seddon, [1994] BCJ No, 1729 (BC SC) at para 26. Because the introduction of such material will generally be contested, it is likely to unnecessarily prolong the case, with added costs to the parties as well as to the administration of justice generally.”